HomeMy WebLinkAbout20200623.tiffCOLORADO
Department of Public
Health Et Environment
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
September 30, 2020
Dear Sir or Madam:
RECEIVED
OCT 0 2 2020
WELD COUNTY
COMMISSIONERS
On October 1, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for
Enerplus Resources (USA) Corporation - Canadian Slang Well Pad. A copy of this public notice and the
public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
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a.020-06.23
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Enerplus Resources (USA) Corporation - Canadian Stang Well Pad - Weld County
Notice Period Begins: October 1, 2020
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Enerplus Resources (USA) Corporation
Facility: Canadian Slang Well Pad
Well Production Facility
SESW of Section 36, Township 8N, Range 67W
Weld County
The proposed project or activity is as follows: Enerplus Resources (USA) Corporation is requesting to modify
the crude oil storage vessels, hydrocarbon liquid loadout and separator venting sources at an existing well
production facility located in the ozone non -attainment area.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 17WE1204, 17WE1205 Et
17WE1206 have been filed with the Weld County Clerk's office. A copy of the draft permit and the
Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-
permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.Rov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Harrison Slaughter, P.E.
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
Zia
COLORADO
Department of Public
Health 6 Environment
COLORADO
Mr Pollution Control Division
Devarttnent o autilr_ Health 6 Eimrcr rtten;
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 17WE 1204 Issuance: 3
Date issued:
Issued to: Enerplus Resources (USA) Corporation
Facility Name: Canadian Slang Well Pad
Plant AIRS ID: 123/9F50
Physical Location: SESW SEC 36 T8N R67W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TANKS
004
Two (2) storage tanks each with three (3)
400 barrel fixed roof storage vessels
connected via liquid manifold.
Emissions from the
storage vessels are
routed to a sales
pipeline through the
use of a vapor
recovery unit (VRU).
During VRU
downtime, emissions
are routed to
enclosed
combustor(s). The
VRU has a maximum
of 67% annual
downtime.
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
the specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
Page 1 of 12
(COLORADO
Air Pollution Control Division
Oecaar1xnent oR Public Health & T-nvircr mem
Dedicated to protecting and improving the health and environment of the people of Colorado
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may
result in revocation of the permit. A self certification form and guidance on how to self -
certify compliance as required by this permit may be obtained online at
www.colorado.Rov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
2. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
3. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
4. The operator must retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,t
VOC
CO
TANKS
004
---
---
5.4
1.0
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons
per year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve
month total is calculated based on the previous twelve months' data. The permit holder must
calculate actual emissions each month and keep a compliance record on site or at a local
field office with site responsibility for Division review.
6. The owner or operator must use the emission calculation methods and emission factors found
in the Notes to Permit Holder to calculate emissions and show compliance with the limits
Page 2 of 12
COLORADO
Mr Pollution Control Division
De garb -neat tr< PuLk Heakh b ErIvirOrtrtlen1
Dedicated to protecting and improving the health and environment of the people of Colorado
contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice
(APEN) and receive a modified permit prior to the use of any other method of calculating
emissions.
7. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
TANKS
004
Emissions from the storage vessels are
routed to a sales pipeline through the use
of a vapor recovery unit (VRU). During VRU
downtime, emissions are routed to enclosed
combustor(s). The VRU has a maximum of
67% annual downtime.
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
Section II.A.4.)
Process Limits
Facility
Equipment
ID
AIRS
Point
Process
Process Parameter
Annual Limit
TANKS
004
01
Total crude oil
throughput
90,000 barrels
Crude oil
throughput during
VRU downtime
60,000 barrels
02
Combustion of pilot
light gas
0.2 MMSCF
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
9. The owner or operator must monitor and record VRU downtime on a daily basis. VRU downtime
shall be defined as times when emissions from the crude oil storage vessels are routed to the
enclosed combustor(s) rather than the VRU. The total hours of VRU downtime, total crude oil
throughput volume and total crude oil throughput volume during VRU downtime shall be
Page 3 of 12
'COLORADO
Air Potlution Control Division
DeoarRttrr%t o, PuLb_ FleaIchi & Erpovortrilent
Dedicated to protecting and improving the health and environment of the people of Colorado
recorded on a monthly basis. The owner or operator must use monthly VRU downtime records,
monthly crude oil throughput volume records, and the calculation methods established in the
Notes to Permit Holder to demonstrate compliance with the process and emission limits
specified in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) I. E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply
with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by
means of visual observation from the outside of the enclosed combustion device, or by
other means approved by the Division, determine whether it is operating properly.
(Regulation Number 7, Part D, Section I.C.) (State only enforceable)
13. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion
device is used to control emissions of volatile organic compounds to comply with Section II, it
must be enclosed; have no visible emissions during normal operations, as defined under
Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by
means of visual observation from the outside of the enclosed flare or combustion device, or
by other convenient means approved by the Division, determine whether it is operating
properly. This flare must be equipped with an operational auto -igniter according to the
schedule in Regulation Number 7, Part D, Section II.B.2.d.
14. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate
air pollution control equipment that achieves an average hydrocarbon control efficiency of
95%. If a combustion device is used, it must have a design destruction efficiency of at least
98% for hydrocarbons except where the combustion device has been authorized by permit
prior to March 1, 2020. The source must follow the inspection requirements of Regulation
Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of
two years, made available to the Division upon request. This control requirement must be
met within 90 days of the date that the storage tank commences operation.
15. The storage tanks covered by this permit are subject to the venting and Storage Tank
Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section
II.C.2.
16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing
Page 4 of 12
a
COLORADO
Air Pollution Control Division
C€v,'itneoti o Pubic Health b _riworimeni
Dedicated to protecting and improving the health and environment of the people of Colorado
plant in Colorado must submit a single annual report that includes actual emissions and
specified information in the Division -approved report format. The information included in the
annual report must be in accordance with the general reporting requirements of Regulation
Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter,
owners or operators must maintain the information according to Regulation Number 7, Part D,
Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING Ft MAINTENANCE REQUIREMENTS
17. Upon startup of this point, the owner or operator must follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to the OitM plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
18. Within one hundred and eighty days (180) after issuance of this permit, the owner or operator
must complete site specific sampling including a compositional analysis of the pre -flash
pressurized crude oil routed to these storage tanks and, if necessary for emission factor
development, a sales oil analysis to determine RVP and API gravity. The pre -flash pressurized
crude oil sample must be obtained from the outlet of the three-phase separators. Testing must
be in accordance with the guidance contained in PS Memo 14-03. Results of the analysis must
be used to calculate site -specific emission factors for the pollutants referenced in this permit
(in units of lb/bbl crude oil throughput) using Division approved methods. Results of the analysis
must be submitted to the Division as part of the self -certification and must demonstrate the
emissions factors established through the analysis are less than or equal to, the emissions
factors submitted with the permit application and established herein in the "Notes to Permit
Holder" for this emissions point. If any site -specific emissions factor developed through this
Analysis is greater than the emissions factors submitted with the permit application and
established in the "Notes to Permit Holder" the operator must submit to the Division within 60
days, or in a timeframe as agreed to by the Division, a request for permit modification to
address these inaccuracies.
Periodic Testing Requirements
19. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
20. All previous versions of this permit are cancelled upon issuance of this permit.
21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
Page 5 of 12
COLORADO
Mr Pollution Control Division
De invent o Pubbc Ne31t11 ti Erpor'x!r Ye" 11
Dedicated to protecting and improving the health and environment of the people of Colorado
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on
the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
22. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Regulation Number 3, Part D, VI.B.4/V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
Facility
Equipment
ID
AIRS
Point
Equipment
Description
Pollutant
Emissions - tons per year
Threshold
Current
Permit
Limit
GLENG01
002
SI RICE
VOC
NOx
50
50
18.0
8.5
PRD_WTR
003
Produced
Water
Storage
Vessels
Page 6 of 12
COLORADO
Mr Pollution Control Division
Department a' Purls_ Health b ErivirCtlfrit.17
Dedicated to protecting and improving the health and environment of the people of Colorado
TANKS
004
Crude Oil
Storage
Vessels
LOAD
005
Hydrocarbon
Loadout
Separator
006
Separator
Venting
GEN01-
007
SI RICE
GLENG02
008
SI RICE
VRU
009
SI RICE
___
Insignificant
Sources
tote: APEN and nermit exempt sources do not have oermit limits. However. the PTE of I
hese sources
(excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR.
GENERAL TERMS AND CONDITIONS
23. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
24. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization section
of this permit.
25. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
26. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
27. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
Page 7 of 12
COLORADO
Air Pollution Control Division
oarrrnenr a Public I- tealr.h & Envir Crtrrielt
Dedicated to protecting and improving the health and environment of the people of Colorado
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
28. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Harrison Slaughter, P.E.
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
March 1, 2018
Issued to Enerplus Resources (USA) Corporation.
Issuance 2
January 9, 2020
Modification issued to Enerplus Resources (USA)
Corporation. Final Approval
Issuance 3
This Issuance
Issued to Enerplus Resources (USA) Corporation
Decrease permitted throughput from 135,000
barrels/year to 90,000 barrels/year. Include
limit on pilot light combustion. Add VRU as
control device.
Page 8 of 12
COLORADO
Air Pollution Control Division
De anrne•3t a Pub b_ Health B Enolrovneni
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the
Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(Ib/yr)
Controlled
Emissions
(lb/yr)
004
Benzene
71432
2,344
78
Toluene
108883
659
22
Ethylbenzene
100414
64
2
Xylenes
1330207
180
6
n -Hexane
110543
13,848
462
2,2,4-
Trimethylpentane
540841
491
16
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 9 of 12
'COLORADO
Air Pollution Control Division
Derertment a Putt t'(@131[tl Er rtvir G'rlm&'ri.
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Point 004:
Process 01: Crude Oil Throughput
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/bbl)
Controlled
Emission Factors
When Emissions
are Routed to
the VRU
(lb/bbl)
Controlled
Emission
Factors
During VRU
Downtime
(lb/bbl)
Source
CO
2.95x10-2
---
2.95x10-2
AP -42
Chapter
13.5
VOC
3.588
0.00
1.794x10-1
EEtP Tank
Version 3.0
71432
Benzene
2.604x10-2
0.00
1.302x10-3
108883
Toluene
7.319x103
0.00
3.659x1O4
110543
n -Hexane
1.539x10-1
0.00
7.693x1O3
540841
2,2,4-
Trimethylpentane
5.452x1O3
0.00
2.726x104
Note:
The controlled emissions factors for this point are based on a control efficiency of 100% when
emission are routed to the VRU and a control efficiency of 95% when emissions are routed to the
enclosed combustor(s) during VRU downtime. The site specific emission factors for this source
were developed using a site specific pressurized liquid sample in conjunction with E&P Tank
version 3.0. The pressurized liquid sample used as an input for the E&P Tank simulation was
obtained from the outlet of the three-phase separator for the Maple 8-67-36-25C well on
10/09/2017. The sample temperature and pressure are 83°F and 21 psig respectively.
Uncontrolled actual VOC and HAP emissions are calculated by multiplying the emission factors in
the table above by the total crude oil throughput. Controlled actual VOC and HAP emissions are
calculated by multiplying the uncontrolled emissions by a 100% control efficiency when emissions
are routed to the VRU and a 95% control efficiency when emissions are routed to the enclosed
combustor(s) during VRU downtime. The AP -42 Chapter 13.5 CO emission factor (0.31 lb/MMBtu)
in the table above was converted to units of lb/bbl using a GOR of 39.5285 scf/bbl and heat
content of 2,405.16 Btu/scf. Actual CO emissions are calculated by multiplying the emission
factors in the table above by the total crude oil throughput during VRU downtime.
Process 02: Combustion of pilot light gas
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
CO
432.14
432.14
AP 42 Chapter
13.5
Note: The CO emission factor above was obtained by multiplying the AP -42 Chapter 13.5 CO emission
factor (0.31 lb/MMBtu) by a higher heating value of 1394 Btu/scf. Actual emissions are
calculated by multiplying the emission factors in the table above by the total fuel flow of the
pilot light gas. Pilot light gas fuel flow is based on a constant rate of 11 scf/hr. There are a
Page 10 of 12
Air Pollution Control Division
De•.aantnent of Pubic Health & _rtvircr o
Dedicated to protecting and improving the health and environment of the people of Colorado
total of two (2) enclosed combustors used to control emissions from this source. As a result, the
total pilot light rate is 22 scf/hr. The total volume of pilot gas flow is determined by monitoring
the hours each enclosed combustor operates with an operational pilot light.
Total actual emissions are obtained from the sum of emissions resulting from the crude oil
throughput (process 01) and the combustion of pilot light gas (process 02).
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and
associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A)
when applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, NOx, CO a n -Hexane
PSD
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC &t NOx
MACT HH
Area Source Requirements: Not Applicable
Major Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.Rov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
Page 11 of 12
COLORADO
Air Pollution Control Division
nennt a' PuhWK Hzaltli t, =rrfrr_tlrif 5S
Dedicated to protecting and improving the health and environment of the people of Colorado
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 12 of 12
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package 6:
Received Date:
Review Start Date:
For Division Use Only
Harrison Slaughter
423294
12/18/2019
9/2/2020
Section 01- Facility Information
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility: Exploration & Production Well Pad
What industry segment Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? Yes
If yes, for what pollutant? Ozone (NOx. & VOC)
Enerplus Resources (USA) Corporation
123
9F50
Canadian Slang Well Pad
Weld County
Section 02 - Emissions Units In Permit Application
Leave Blank - For Division Use Only
AIRs Point it
(Leave blank unless
APCD has already
assigned)
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
(Leave blank unless
APCD has already
assigned)
Issuance
#
Self Cert
Required?
Action
Engineering
Remarks
004
Storage Tank
TANKS
Yes
17WE1204
3
Yes
Permit
Modification
Quadrant
Section
Township
Range
SESW
36'`
8N
67
Section 03 - Description of Project
Enerplus submitted a permit application to modify sources at an existing major well production facility. With this application, the operator is requesting to modify
the crude oil storage vessels, hydrocarbon loadout and separator venting sources. This analysis only evaluates the crude oil storage vessels.
With this application, the operator is requesting to decrease the permitted throughput from 135,000 barrels/year to 90,000 barrels/ year. In addition, the
operator is requesting the use of a vapor recovery unit (VRU) to control a portion of the emissions. This request correlates to emissions associated with 30,000
barrels of production being controlled by the VRU and the emissions associated with the remaining 60,000 barrels of production are routed to and controlled by
the enclosed combustors.
Public comment will be required for this permit modification because new synthetic minor limits are being established. In other words, the facility emissions are
now below the serious non -attainment threshold of 50 tpy.
Self -certification for the first issuance of this permit was received on 08/17/2018 and approved on 08/20/2018. As a result, thesecond issuance of this permit was
issued as final approval. Initial testing is required in this permit. As a result, the permit will be required to go back through the self -certification process.
Sections 04, 05 & 06 - For Division Use Only
Section 04- Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 -Ambient Air Impact Analysis Requiremer
Was a quantitative modeling analysis required? No
If yes, for what. pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes, indicate programs and which pollutants: 5O2 NOx CO
Prevention of Significant Deterioration (PSD) OOOO
Title V Operating Permits (OP) ❑ O O
Non -Attainment New Source Review (NANSR) O
Is this stationary source a major source? hto
If yes, indicate programs and which pollutants: S02 NOx -- CO
Prevention of Significant Deterioration (PSD) ❑ ❑ ❑
Title V Operating Permits (OP) OOOO
Non -Attainment New Source Review (NANSR) ❑
VOC
O -
0 -
VOC
❑
❑ -
PM2.5 PM10 TSP HAPs
❑ ❑
O ❑ ❑ O
PM2.5 PM10 TSP HAPs
❑ O
❑ DOD
to:ageEmissions inventory
section D1-Aamim5trative Information
'Facility AIRS ID:
n
County
PESO
Plant
000
Point
Section 02 -Equipment Dew... Details
Storage Tank liquid
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Two (2)storage tanks each with three 13)400 bbl fixed roof storage vessels connected v. liquid manifold.
Vapor recovery unit(YRU)routes emisslonsto pipeline. Emissions are fruited to enclosed combustorls) during VRU downtime.
Requested VRU Control Efficiency %:
Requested Enclosed Combustor Control Efficiency %:
VRU Downtime %:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Section 03 Rah Information for Emissions Estimates
Primary Emissions -Storage Tank(s)
tual Throughput=
Actual Throughput During VALI Downtime=
(Requested Permit LimitThroughput=
Requested Permit timitThr2ughput During VRU
Downtime=
Potential to Emit (PTE) Throughput =
Potential to Emit (PTE) Throughput During VRU
Downtime=
Secondary Emissions -Combustion Devices)
Heat content of waste gas=
Volume of waste gas emitted per BBL of liquids
produced=
Actual heat content of waste gas routed to combustion device=
Requested heat content of waste gas routed to combustion device =
66.67
y0000 -Barrels Ohl) per year
Xi, RBarrels (bbl) per year
0,000.0Barrels (bbl) per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device
Control Device
Barrels (bill) per year
Barrels (bbl) per year
Barrels (hill) per year
bbl
Requested MonthlyThroughput= 0_i23 Barids (bbl) per month
4-3 MMBTU per year
...'1, MMBTU per year
5 fraT MMBTU per year
Secgan 04-Emizsl0ns Factors &Methodologies
Will This storage tank emit flash enassiom?
E&P Tank Flow Rate
135,000.00 bbl/year
Pollutant
Emissions pay)
VOC
:167
Benzene
58
Toluene
00105enzene
01)015s
n -Hexane
0.115
10.386
2,2,4TMP
0.368
Emission Factors
Crude OR Tank
Uncontrolled Controlled
Pollutant
(Ib/bbp (lb/bbl)
Emission Foam -Source
(Crude Oil
(Crude Oil
Throughput)
Throughput)
VOC
.3.-.,'
8510 t i�
Benzene
_�A5p
Toluene
Ethylbenzene
a
Sih Sptttik F.F. (Isitlu 0s` )
Xviene
Me retE:F. (inci020211 hl:-
She Specific F.F {idcludez [lash)
ndiexane
220TMP
_
i,F t-:i
3HeSpecifk E.F.lo,o100 s2420)
control Device
UncontrolledIncontmlled
Pollutant
(0/MMBtu) (lb/bbl)
Emission Factor Source
(waste heat
combust.)
(Crude Oil
Throughput)
PMI0
-0.0075'..
_
r0P4UTable 1.4.2(00610/PM,2.51
PM2.5
0.0075
:
AP -02 Tablet32(PM20/PM.2.5)
SOx
0.0006.
T bl 142(50x/
x
00680 -
-
A .02 Chapter0B.sf dusts IFares INO )
CO
i 03300.
__
AP.02CIIapdy435,104g214tobclaros(CO)
Pilot light Emissions
Uncontrolled Uncontrolled
Pollutant
Ilh/MMBtuI fib/MMsc&
Emission Factor Source
(Pilot Gas Heat
(Pilot Gas
Combusted)
Throughput)
PMIO
00075
R-0 bl 3 4-21Pg9I6 R -at
AP 2T bl 1..2 (Pia
PM2.5
0.0075
SOx
.00006
211.42T bl 1.42(5
NOB
68 .00
AP-42Chapter 13.3, 04
AP42Tb104-4 A/ R
O
0.0064
CO
_09300
c
AP -42 Cheraw
Section 0 -Emissions Inventor%
Controlled Emission Factors Used a Permit
Pollutant
Controlled Emission Factors used during VRU
operation (Ib/bbl)
Used During VRU. Downtime
(Ib/bbl)
Source
V0C
1.00
Site specific E.F.
Benzene
,, 0
Site specific E.F.
Toluene
0 06
...specific E.F.
Ethylbenzen
Site specific E.F.
Xylem
site spiaificE.P.
n -Hexane
2 3
Slle specific E.F.
224TMP
....
_-
Site specific E.F.
Criteria Pollutants
Poh6Ual to Fruit
Uncontrolled
(tans/year)
Actual Emissions
Uncontrolled Controlled
(tom/year) (tom/year)
Requested Permit limits
Uncontrolled Controlled
(tom/year) (tons/1041)
Requested Monthly Limits
Controlled
(Ibs/month)
PME.5
SOx
NOx
Vac
2313
0.622
:E
:
0.002
-
—
5.,1.
914)
Hazardous. Pollutants
Potential to Emit
Uncontrolled
Ilbs/year)
Actual Emissions
Uncontrolled Controlled
1110:/yosd llhs/veer)
Requested Permit Limits
Uncontrolled Controlled
1Ibs/yeer) (Ibs/year)
Benzene
Toluene
Ethylben e e
n -Hexane
224 TAM
234,00
..ill
_?
23.06
r
2. I'.3
6,00
I,SEZlo
29..67
10,36
-.0-1_.
1....C
C\Users\h410250t\Desktop\1239F50\I7WE2204.CP3
Section 06 - eeulaton' Summary Analvsk
Regulation 3, Part A, B
Regulation 7, Part 0,Sect 50 I.C, O, E, F
art0.20ee.r--.
Regulation 7, Part D,Sectionl.O,0
T.
zo
Regulation 7, Part 0,5ectlon 0,[1, 0.3
prat tend,
Regulation 7, Part OSecton I.C2
Storage can.
Regulation 7, Part .Section Caa(t
5.reee 100 -.
011,'
lsg2let,vrr 7, Parta(k)
2,,r,. a -
t0
Regulation 6, Parta, NSPS Subpart Kb
hconolsithl ,_,.
Regulation 6, Part'', NSFS Subpart OOOo
,,erx ne1,1,_.
NSPS Subpart 0000a
T
Regulation S. Part E. MRCT Subpart HH
(see regula.ry applicability coorkaheetfor detailed analysis)
Section 01 -Initial and Periodic Sampling and Testing Requirements
For condensate or crude oil tanks, does the company use the state default emissions factors to
estimate emissions? NO ,
If yes, are the uncontrolled actual or requested emissions fore etude oil tank estima tied to be greater than or equal It 20 tom VOC per year OR are the uncontrolled
actual or requested emissions fora condensate storage tank estimated to be greater Manor equal toga Ipy?
If yes, the permit will contain an"Initial Compliance" testing requirement. develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company use a site specific emissions Ftor to estimate emissions?
�._Ye, •
if yes and if there are flash emissions, are the emissions factors based on pressurized liquid sample drawn at the facility being
permitted (for produced water tanks, a pressurize liquid sample most be analyzed using flash liberation analysis)? This sample
should be considered representative which generally means site -specific and collected within are year of the application received
data However, If the facility has not been modified (e.g., no new wells brought an-lim),then it may tie appropriate to use an older
tie -specific sample.
If no, the permit will contain an"Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03,
Does the company request a control nevice efficiency greater than 95%for a Aare or combustion device?
thy., the permit will contain Inktal and periodic complioeee.sting In accordance with PS Memo 20-01
No _.
N/A -the operator developed site specific emission factors.
Section 08 -Technical Analysis Notes
1, eccordog to Me APEN, two wells produce to this facllity.The well names and API numbers areas follows: (l) Name: Maple 8-67-39250, API: 05-123d4539,and ( ) Name: Beaufort 8-6]-36-250,API 55423-40010- The Maple well was fractured and began production in
August2017.This well produces from the Cadge, Codeil and Fort Hays formation. The Beaufort well was fractured in July 2019 and began production in Sephmber 2019. COOCC data does not provide information on Me formation from which this well produces CO1CC
data indicates the API gravity for each welds less than 40. Asa result, the ciassificotionas crude oil is appropriate. - -
2.The sample used to establishemission Factors was obtained 6.m [he outlet of the three-phase separator for the Maple 8-67-36-25Cwell on 10/09/2017.Thfs sample was used to develop the emission factors approved with the previous issuance of this permit The
emission factors will continue to be approved with this issuance of the permit However, the sample used to develop the emission factors was obtoined prior to the completion of the second well at lhh facility(Beaufort e -67-36.25C). Since the ample was obtained prior
to the completion of all the wells at this facility, the permit will contain an initial sampling requirement to confirm the previously established emission factors remain cnioetvatfve or accurate with the added m0ducton of the second well.' location
3. The specific ample was used in Conjunction',than E&P Tanks v.3.0 simulation to determine slh specific emission factors soil combustion emissions. The results of the E&P Tank simulation (i.e. emissions Roy), GOParid heat content) are available forreierencen
Sections 03 and 04 above. It should berated that the OrigInal simulation inwnectly listed the separator pressure input vel wain units of pslg rather than psia and the ambient pressure as 147psa rat.er than ambient pressure assaer. with the Denver area the. 12.1-
12.5 psia). As a result, the operator provided an updated simulation with the separ9or pressure updated to reflect value of33.1 psis (21 psigt12.1 psle) and the emblem pressure as 11.1 psla. This simulation resulted in less conaervattve emission data, Therefore, the
originally approved 5000150 factors areaccepthble for continued use,
A The crude oil ztoragevesah, produced water storage vessels and loadout operations are controlled by the same two enclosed combustors. Asa result engineering guidance indicates that combustion emissimts (i.e NOx and CO) from all the sources are summed
together in order to determineAdo,vroBce0lily. Inthistotal COpe00000 fromag the sources are above APES reporting thresholds. As a result. Use permit for each source should contain emission limb and emission factors for CO. Total NOx emissions from the
audedl storage vessels, produced wa.rstwage vessels and loadaut operations are below APES reporting thresholds.
S.Since theceude oil storage vessels, produced water storagevessels andloedout are controlled by a 0mmon control device, pilot light emissions are grouped with the highest emitUng source covered by an individual permit In this case, the crude of storage vessels are
thehighest emitting source. Asa 'molt pilotlight emissions are accounted for with this analysts. The permit for the crude oil storage vessels also contains throughput limitfor pilot combustion Emission factors and calculation methods for pilot light comha0on
emissions ere also Ilcluded in the notes to -permit holder. This information Is Included In the permit because pilot light emissions cantribuh to the overall emissions from this source. Additionally It is Important Minch's. this Information because throughput tracking and
emission calculation methods are different than those used to estimateemlsstm based on the Node NI throughput This clarity is important for accurately quantifying actual emissions at this facility.
•
6.Selfcertl'cat len for the first issuance of the permit was submitted on 08/17(201aand approved on 08/25/20238 As a result the :initial opacity testing Included in the first issuance were removed In the previous lssuanceof the permit and will not be included inthis
permit Additionally, ongoing opacitytestng isaddrmsed by the 0&M plan.Asa result, periodic opacity resting is notintl islet) in this permit
P. A VOC emission factor for pllotlightcumbuston is not Included in the permit because the toralVOC emissions associated with pilot fight combustion are negligible (0.001 toy) and do not impact the overall VOC emssions.
8. An updated APEN was submitted in March 2020. This APEN Indicates that a portion of emissions are captured using a vapor recovery unit (VRU). According to the operator, emissions from the storage vessels are routed to e sales pipeline through the use of a vapor
recovery unit (VRU) during normal ...don. hiring VRU downtime, emissions from the storage vessels are routed to eaload combustor(s). The operator has indicated the vapor recovery units are down for 67%ofthe time during the calendar year. Oaring VRU
operation, the operator has requested a control efficiency of 10096. During VRU downtime, to operator has requested a 9188 control efficiency for the enc.sed e5mbustor(s). Since the control devices have different control efficiencies the operator will be required to
track VRU downtime in conjunction with hydrocarbon throughput during VRU downtime in order to demonstrate ongoing compliance The permit will contain a VRU downtime tracking condition In conjunction with a process limit on hydrocarbon liquid throughput during
)VRU downtime.
9111e permit will contain two process limits with regards to crude 011 throughput One limit will reference total requested crude oil throughput 190,000 banes/year). The second Ilmit will reference total crude off throughput during VRU downtime (60,000 betel/year). The
o� limit on total crude oil throughput Monporetes all the throughput that occurs while the VRU 's operational. In the event the V0. ha hss than 61% downtime e. the crude oil throughput during VRU downtime is less than the requested limIll9he operator should
remain
compl once with the emission limit because the VRU is requesting a l00%control efficiency compared to the 95% control efficiency associated with the combmtor(s). As a result, less VRU downtimes beneficial both for the environment and the operator. m •
10. Ethylbemene and 0/ rte are the only HAPS below APES reporting threshold (i.e. 750 lb/year). As a result the permit will not contain emission factors for these HAPs.
The NOS for this source was provided on 03/07/2018. As a result. an updated NOS isnot required as part of the self -certification requirements in the permit
12. The controlled VOL and NAP emission factors In Section 04 above are based on the overall control efficien, associated with the VRU (100% control) and enclosed combustors) (95%rontroll. However, these emission factors are not the values that will be in the Notes
, ') toPermit Holder section of the permit The Notes to Permit Holder in the permit contains two sets of controlled emission Ftors. The first set represents controlled emission factors that must be used when emissions are muted to the VRU. Since a b00%c0ntroi efficiency
is applied when emissions are routed to the VRU, the emission factors for this scenario are all represented as 0.00Ib/bb0 The second set of emission factors represents trolled emission factors that must be used when emissions are routed to the erclosedc0mbustor(sl
during VRU downtime. These emission factors represent the uncontrolled emission factors multiplied by 9596 control efficiency. The controlled emission factors represented in the permit are calculated Ina table in section 04 above label. ',ono -oiled Emission Factors
Used In Permit'
13. The operator was provided with¢ draft permit and APES redline to review prior. public comment The operator reviewed 60th documents and provided comment. The operator's comments and the Division response are available in the email records that have
been uploaded to Records Manager.
Section o9 -SOP 0531ng and Emissions Factors IFor Inventory Use Onlvl
AIRS Point ft Proceed SCC Code
01 4OilO. 042,28688 2fw0TathaOhlanhilaSaSteoe
Pollutant
PM2.5
spa
NDx
VOC
CO
Bergelle
Toluene
Ethylhenaene
gylene
n -Hexane
224 TMP
Uncontrolled Emissions Factor Control%
anF -13
Units
Nation gallons Crude Oil throughput
b/1,OSo gallons Crude Oil throughput
b/1,000 gallons Crude Oil throughput
6/1,000 gallons Crude Oil throughput
b/1,o0o gallons Crude Oil throughput
b/1,005 gallons Crude Oil throughput
b/1,000 gallons Crude 00 throughput
6/1,000 gallons Crude Oil throughput
b/1,000 gallons Crude Oil throughput
b/1,000 sonars Crude Oil throughput
6/1,000 gallons Crude Oil throughput
0/1,000 gallons Crude oil throughput
3 of C:\users\hslaught\Desktop\1239F55\32WE3204.CP3
Storage Tank Regulatory Analysts Worksheet
The regulatory requirements below are determined hosed on requestedemisslons.
AnunrgERT
1. Are uncontrolled aqua emissions/ram any [Merle pollutants lmmmle Individual sew= greater than x TnlReewl,tlon]Part ',Sectionn.Da.alr
construction0142014 and not maadnaatter41444 wth a aenaetanbmrouehilut lea. than 4aapovRon, per year l:eeP:7deme14mvoraadagnal6.Wanceaneranantherapplwbmt02
3. Are to i. coniolled vuC emtnlom greater Mar,TPV..Ua greater Man loin or CO emwmes 6eaW.,n 10Tn lllegubtm3,Parte,2ennnll..ap
tai.. ... .. . ... ,
Hn Mn,iaRmar
2. Are uncontroed enessumalrom anyerPeriapolimants.fromt.mdmelualseumegrearernan1D, lRervntwn3.Pan A.senlonll.o.i.alx
3 Is the (04/14/2014 and nor moamm aner v14n4 wax a storage tank throughput teas man 40.000gallons per year ISee n m ems 14-04 for additional guidance enennatamee appllaabmrvp
3. Ares constructiondare
vet emissions. p er than 3T7Y greater than shay or emraoes greater than 201,1, IN.m.R, Part e,seaiomLD.xp
1. Is this storage tank located n the ahravant control area orany e,one nen.analement area or atmnmendmalntmmm area2Nlaxan L Part D. semon
Ism.3
....rage,. located at elle. em perallanamat collect.stare, eve handle hydrocarbon or produced water arvo32marast re located gar upstream222°fa natural gas pmcess.gpbat lReg.lamn7. Part D. Seaton I.A.3B
p. [me -stn. storage rank contain condeneatai
ra ill" storing no,atahrn liquids] emrssronsPiegulatlon7. part D,xatgn 1..17
2. Are uncontrolled actual emis.nsuf cola stooge tank equal o or greater than Ito. pdrvear VOCIReeulatmn 7, Part D..earen m.3aa017
nuon Lea
Part %Section I.C.2.-Emmon Estimation Procedures
Part Sactien anti lk -General Requirements br Air pallubon centred Dz.,. -Prevent. nfleakaee
Colorado lieetilatim 7, Part D Menu
1 Is this storage tanl, located at a nmalsto
2. Is MIsstoragelan0 located at an , well production mrnmy. natty pr r,tamnornn.lale larnesangplant^wesmatlon 7,pa n,Ranlonnen
3. Doestlus storage tad have a Ned all
,�m°I��azPart o�Sr ��ta:n�xe
4. Pre n t .actual em.uonaetm. storage tank meal to orpreaterman a Ions per yearvac lReeuexon7.Parto,eernon ll.e.i.rli
Pan', Section 11.[.3.P.oraeepIng Requirements
s. Dem. rage tank contain only bilka q IP2mhuon',Parro.sednnlle22R
Is Um contrelletl storage...Wed at a well production faciln.v.natural gas compressorstation.ar natural gas processing plant constructed ',nor after May ;202,2er located al at acaythat wasmodif red on or alter may1,20.
Go to n.1 guest.
Comm@ •Vou have Indi,ated Me sae attaMment status .the prole. summery sheet.
-You have mdleatea the mnra category on. Naga Summary sheet,
Go to tile next nuestIon • u have rndrmteel fatuity type an project summarysheet.
Go tot. geas.M
Source Is 2221222112 parasol 3322la(1237.Part 0.seaons lhB&g. Go to. neat questIon
IRa-- -fffso rednmbpat p mans al Regulate., Part ',Seru, ll,sobseeuon43&e
Ra...: jYeaRTxh isnotaped re Reeoaren 7,Parr smmn II c4
isthe controlled slorage WO located at+ well procluctum /auk, natural ess compressor statirm.or natural eas processing 7. 1,202 jean atl.tlonal controlled aoraee vessel is mnstrunealo remove anu p .increase in throughput plant
of hydrocarbon lqugrartwas meitleneratter»n
predued WAe..platten l.Pano.senlon II CAA
ry NPe 1.1
1. is the mtlitclual stoup, vessel taped, arman or equal la lS cubla meteralm'I 1-4rzeelI14ucm20.2,0nlal17
x, Does .1m1a111.
a. Doe,. vessel has. design p yless man r q e1,ses.n4 re (-10000 Day us. tar petroleum or condensate norea,procenea,orrreateaenorm m.wdv.anslm as defined m 20.11107
Estilesto.meevesulMa I -2a pail and mionso the atmosphere I60110POllall, or
capacity is greater than or m'I-es 2211 and stoma liquid wan amnlmum true yapo. praum'less than 2 SFr, ,50
c. 'Madame. opaaty greater Manor eeual to m'( -4n earl girt lessroanu1n;(-am eey and stares a aquiawi. a maim., qua vapor pressure less man 2500 aama11W1063
7. ideaa. The fles. capacity is greater than tank meet either one of thOollaVMS
re mFa.o aelnand store. (quid wire a maximum true uapar premre greater man or equal In 3.s la. lessman sx kPa,or
b. The design ,paely Kreger limner equal to 7e hl' 1-472 get] but less.an ss1 W,350 age) and stores. Num . a manmumtme opal' pressure ereaterthan eve equal to leer ItPabut en than27.ekPa7
2733, Pan So. Subpart 2042/04202.2nnder& :(347 nnance or 77.62 De anti 72(2/2/626 Pm62(21en.Tnmm(ai23 and gsWbuxoq
. timi.raee vessel located al a batty in the onshore ell and Pu
W. ...wage vessel constr.,. rewnnmgea,er Am. led (see ae6txm n 4oe2ReAu
ea.xl between 23. 3011and September s processing segment or natural am snonand storage xgnentafinelndurtryi
le2015,
storagethan ar equal. 6 Derstins storegevessel meet the definition orsloraee vessel'. han are tons peryeanIs the rtnrase vessel 'Waled to and controlled in accordance WO requirements lerstor e vessels in 40 Cf Pare 605uhraart kla or 40CFRPart 63 Sub art MO
Irvin mnusly deteeminea to buableatwq3767703/oo00a duster eminlom above 6 ton peryea7/00 on Ma apmlm636v determ1nau.n 612,0,6326 mm136641egmrvs760000/0070a per
2n.:.liann/26.53•65614121 emn a p. mlalwcemba.n drop below 2tons imp.]
Part63, Subpart MCI' ON and Gas Production facilkies
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atom patn2 me point atm. natural enenm..enmra esstranuntrvon and storage rearm categoryor is delivered to a nna end ow la3.7601021p
ts the lank located. at atacihry that is maier. For NO.Ps2
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COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
Enerplus Resources (USA) Corporation
County AIRS ID
123
Plant AIRS ID
9F50
Facility Name
Canadian Slang Well Pad
History File Edit Date
Ozone Status
Non -Attainment
EMISSIONS - Uncontrol ed (tons per year)
EMISSIONS With Controls (tons per year)
POINT
AIRS ID
PERMIT
Description
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACILITY TOTAL
Previous Permitted Facility total
..
-
001
GP02.ON' _...
SI RICE Duosans1I, NA, 4SRB, 118 HP,SN.
EEPOF3SI280
0,4
0.0
Cancellation received 08100/2018, Source da longer exists
at the facility.
002
19WE0536
SI RICE Caterpillar G3306TB, 4SRB, 203 HP,
SN: R6S00735
0.2
0.2
30.0
1.4
30.0
0.6
0.2
0.2
2.0
1.4
4.0
0.3
No Change
003
17WE1203
One (1) 400 bbl fixed roof produced water
storage vessel
0.3
20.0
1.3
2.2
0.3
1.0
1.3
0.1
No Change
007
19WE0537
SI RICE Doosan 8.L CAC, 4SRB, 199 HP,
SN: EEPOG-402082
0.2
0.2
20.8
1.4
35.0
0.3
0.2
0.2
2.0
1.1
3.9
0.1
No Change
008
19WE0791
SI RICE Caterpillar G3306TA, 4SRB, 203 HP,
SN: O6X00250
0.1
0.1
28.3
1.4
28.3
0.6
0.1
0.1
2.0
1.4
4.0
0.6
No Change
009
20WE0685.XP
SI RICE Zenith ZPP NA 416, 4SRB, 36.8 HP,
SN: 021307
0.0
0.0
2.2
0.2
3.7
0.0
1.0
0.2
1.7
0.0
New Source - processed by XP pilot program. Emissions
based on APEN submitted on 07/13/2020
XA
Pigging
0.5
0.0
0.5
0.0
Insignificant Source
XA
Heaters
0.6
0.5
0.0
0.6
0.5
0.0
Insignificant Source
XA
Fugitives
0.1
0.0
0.1
0.0
Insignificant Source
0.0
0.0
0,0
0.0
FACILITY TOTAL
0.6
0.6
0.0
0.0
82.8
325.5
0.1
102.2
15.6
. 0.6
0.6
0.0
0.0
8.5
18.0
0.1
18.9
1.6
, ,
Permitted Facility Total
0.6
0.6
0.0
0.0
80.0
324.8
0.0
98.0
15.5
0.6
0.6
0.0
0.0
6.9
17.2
0.0
16.7
1.5
Excludes units exempt from permits/APENs
(A) Change in Permitted Emissions
-0.5
-0.5
0.0
-0.1
-5.6
-79.0
0.0
-25.0
Note 1
Total VOC Facility Emissions (point and fugitive
(A) Change in Total Permitted VOC emissions (point and fugit ve)
18.0
-79.0
Note 2
Page I of 2
Printed 9/29/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name,
County AIRS ID
Plant AIRS ID
Facility Name
Enerpius Resources (USA) Corporation
123
9F50
Canadian Slang Well Pad
Emissions - uncontrolled (lbs per year)
POINT PERMIT Description
Formaldehyde
Acetaldehyde
AGrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTALIrryl
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
4 g
9P S d
''.
SI RICE Doosan 8.1L NA 4SRB 118
((P,EN; EEPOF301280
0.0'
002
19WE0536
SI RICE Caterpillar G3306TS, 4SRB,
203 HP, SN: R6000735
941
45
42
_o
46
0.6
003
17WE1203
One (1) 400 bbl fixed roof produced
water storage vessel
1071
3366
22
004
17WE1204
Soc (6) 400 bbl fixed roof crude oil
storage vessels
2344
659
64
160
13846
491
8.8
005
17WE1205
Hydrocarbon Loadout
VS
18
5
389
14
0.2
006
17WE1206
Flaring of natural gas from two (2) two-
phase separators and two (2) three-
phase separators
_.
298
458
628
832
3460
89
4
2.9
007
19WE0537
SI RICE Doosan ELL CAC, 4SRB, 199
HP, SN: EEPOG-402082
385
52 4
49.4
20,7
: 7.5
0.3
008
19WE0791
SI RICE Caterpillar G3306TA, 4SRB,
203 HP, SN: G6X00250
980
41.6
39.2
23.5
10.6
0.6
009
20WE0685.XP
SI RICE Zenith ZPP NA 416, 4SRB, 36.8
HP, SN: 021307
409
0.6
52
31
41
00
XA
Pigging
0.0
XA
Heaters
0.0
XA
Fugitives
0.0
0,0
0.0
TOTAL (tpy)
1.2
0.1
0.1
1.9
0.6
0.3
0.5
10.5
0.1
0.3
0.0
0.0
15.6
'Total Reportable = all HAPs where uncontrolled emissions > de minim us values
Red Teg uncontrolled amlVolons o de comma,
Emissions with controls (lbs per year)
POINT PERMIT Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL(tpy)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
4UN
I'Q2 N
0431q506010.6:10...t;
HP;tRZ: ep-u3PP35421}0. _.';.
_
002
19WE0536
SI RICE Caterpillar G3306TB, 4SRB,
203 HP, SN: R6000735
470
22
21
13
24
0.3
003
17WE1203
One (1) 400 bbl fixed roof produced
water storage vessel
54
168
0.1
004
17WE1204
Suc (6) 400 bbl aced roof crude oil
storage vessels
. 78
22
2
6
462
16
0.3
005
17WE1205
Hydrocarbon Loadout
R
0 I
02
13
00
0.0
006
17WE1206
Flaring of natural gas from two (2) two-
phase separators and two (2) three-
phase separators
15
23
31
42
173
4
0 2
0.1
007
19WE0537
SI RICE Doosan 8.L CAC, 4SRB, 199
HP, SN: EEPOG-402082
193
20 2
24 7
14 8 '
28 8
0.1
008
19WE0791
SI RICE Caterpillar G3306TA, 4SRB,
203 HP, SN: G6X00250
980
416
39.2
23.5
456
0.6
009
20WE0685.XP
SI RICE Zenith ZPP NA 416, 4SRB, 36.8
HP, SN: 021307
40.5
_.
50
0.2
3.1
15.1
0.0
XA
Pigging
0.0
XA
Heaters
0.0
XA
Fugitives
0.0
0,0
0.0
TOTAL (toy)
0.8
0.0
0.0
0.1
0.0
0.0
0.0
0.4
0.1
0.0
0.0
0.0
1.6
2
1239F50 9/29/2020
COLORADO
Mr Pollution Control Division
cwaftrtient o Pubic Ffea1th b rnv rcruTie 7
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 17WE 1205 Issuance: 3
Date issued:
Issued to: Enerplus Resources (USA) Corporation
Facility Name: Canadian Slang Well Pad
Plant AIRS ID: 123/9F50
Physical Location: SESW SEC 36 T8N R67W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
LOAD
005
Hydrocarbon liquid loadout from
storage vessels to tank trucks using
submerged fill.
Emissions resulting from
the loadout operation are
captured using vapor
balance. A vapor recovery
unit (VRU) routes these
emissions to a sales
pipeline. During VRU
downtime, emissions are
routed to enclosed
combustor(s). The VRU has
a maximum of 67% annual
downtime.
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
the specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. This construction permit represents final permit approval and authority to operate this
emissions source. Therefore, it is not necessary to self -certify. (Regulation Number 3, Part B,
Section III.G.5.)
EMISSION LIMITATIONS AND RECORDS
Page 1 of 12
'COLORADO
Mr Pollution Control Division
Lk't anrriZ" i1 6" Pub Health b _rivitrcrrne..i1.
Dedicated to protecting and improving the health and environment of the people of Colorado
2. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4)
Annual Limits:
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
N0,V0C
CO
LOAD
005
---
---
0.2
0.1
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons
per year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits for both criteria and hazardous air pollutants must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve
month total is calculated based on the previous twelve months' data. The permit holder must
calculate actual emissions each month and keep a compliance record on site or at a local
field office with site responsibility for Division review.
3. The owner or operator must use the emission calculation methods and emission factors found
in the Notes to Permit Holder to calculate emissions and show compliance with the limits
contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice
(APEN) and receive a modified permit prior to the use of any other method of calculating
emissions.
4. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Equipment
ID
AIRS
Point
Control Device
Pollutants Controlled
LOAD
005
Emissions resulting from the
loadout operation are
captured using vapor balance.
A vapor recovery unit (VRU)
routes these emissions to a
sales pipeline. During VRU
downtime, emissions are
routed to enclosed
VOC and HAP
Page 2 of 12
COLORADO
Mr Pollution Control Division
ek;a rvtt.^ii OP Pubk Health 5 Envtrortm •,t
Dedicated to protecting and improving the health and environment of the people of Colorado
combustor(s). The VRU has a
maximum of 67% annual
downtime.
PROCESS LIMITATIONS AND RECORDS
5. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rate must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part
B, Section II.A.4)
Process/Consumption Limits
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
LOAD
005
Total hydrocarbon liquid loaded
90,000 barrels
Hydrocarbon liquid loaded during VRU
downtime
60,000 barrels
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
6. The owner or operator must monitor and record VRU downtime on a daily basis. VRU downtime
shall be defined as times when emissions from the hydrocarbon liquid loadout are routed to the
enclosed combustor(s) rather than the VRU. The total hours of VRU downtime, total
hydrocarbon liquid loadout volume and total hydrocarbon liquid loadout volume during VRU
downtime shall be recorded on a monthly basis. The owner or operator must use monthly VRU
downtime records, monthly hydrocarbon liquid loadout volume records, and the calculation
methods established in the Notes to Permit Holder to demonstrate compliance with the process
and emission limits specified in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
7. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
8. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
Page 3 of 12
COLORADO
Air Pollution Control Division
Depaartient o' Publ4 FNea1U) & Envlrcameni
Dedicated to protecting and improving the health and environment of the people of Colorado
9. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by
using (a) submerge fill and (b) a vapor collection and return system and/or air pollution
control equipment. Compliance with Section II.C.5. must be achieved in accordance with the
following schedule: (Regulation Number 7, Part D, Section II.C.5.a.)
• Facilities constructed or modified on or after May 1, 2020, must be in compliance by
commencement of operation.
• Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021.
• Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the
hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal
to 5,000 barrels per year on a rolling 12 -month basis must control emissions from
loadout upon exceeding the loadout threshold.
10. Storage tanks must operate without venting at all times during loadout. (Regulation Number
7, Part D, Section II.C.5.a.(ii))
11. The owner or operator must, as applicable (Regulation Number 7, Part D, Section
II.C.5.a.(iii)):
• Install and operate the vapor collection and return equipment to collect vapors during
the loadout of hydrocarbon liquids to tank compartments of outbound transport
vehicles and to route the vapors to the storage tank or air pollution control
equipment.
• Include devices to prevent the release of vapor from vapor recovery hoses not in use.
• Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to
transport vehicles unless the vapor collection and return system is in use.
• Operate all recovery and disposal equipment at a back -pressure less than the pressure
relief valve setting of transport vehicles.
• The owner or operator must inspect onsite loading equipment to ensure that hoses,
couplings, and valves are maintained to prevent dripping, leaking, or other liquid or
vapor loss during loadout. These inspections must occur at least monthly, unless
loadout occurs less frequently, then as often as loadout is occurring.
12. The owner or operator must perform the following observations and training (Regulation
Number 7, Part D, Section II.C.5.a.(iv)):
• The owner or operator must observe loadout to confirm that all storage tanks operate
without venting when loadout operations are active. These inspections must occur at
least monthly, unless loadout occurs less frequently, then as often as loadout is
occurring,
• If observation of loadout is not feasible, the owner or operator must document the
annual loadout frequency and the reason why observation is not feasible and inspect
the facility within 24 hours after loadout to confirm that all storage tank thief hatches
(or other access point to the tank) are closed and latched.
Page 4 of 12
COLORADO
Air Pollution Control Division
DE.,.aettient a' Palk Health E=rtvircn
Dedicated to protecting and improving the health and environment of the people of Colorado
The owner or operator must install signage at or near the loadout control system that
indicates which loadout control method(s) is used and the appropriate and necessary
operating procedures for that system.
• The owner or operator must develop and implement an annual training program for
employees and/or third parties conducting loadout activities subject to Section II.C.5.
that includes, at a minimum, operating procedures for each type of loadout control
system.
13. The owner or operator must retain the records required by Regulation Number 7, Part D,
Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division
upon request.
• Records of the annual facility hydrocarbon liquids loadout to transport vehicles
throughput.
• Inspections, including a description of any problems found and their resolution,
required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a tog.
• Records of the infeasibility of observation of loadout.
• Records of the frequency of loadout.
• Records of the annual training program, including the date and names of persons
trained.
14. Air pollution control equipment used to comply with this Section II.C.5. must comply with
Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a
hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi))
15. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing
plant in Colorado must submit a single annual report that includes actual emissions and
specified information in the Division -approved report format. The information included in the
annual report must be in accordance with the general reporting requirements of Regulation
Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter,
owners or operators must maintain the information according to Regulation Number 7, Part D,
Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING Et MAINTENANCE REQUIREMENTS
16. Upon startup of this point, the owner or operator must follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to your O&M plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
Page 5 of 12
COLORADO
Air Pollution Control Division
Lit1@lrtle Putll!_ Hed![fi & znoroirrieni
Dedicated to protecting and improving the health and environment of the people of Colorado
17. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
18. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
19. All previous versions of this permit are cancelled upon issuance of this permit.
20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in
ozone nonattainment areas emitting less than 100 tons of VOC or NO. per
year, a change in annual actual emissions of one (1) ton per year or more or
five percent, whichever is greater, above the level reported on the last APEN;
or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted.
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
21. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
Page 6 of 12
COLORADO
Air Pollution Control Division
cepartmeni a' Pub lr_ tiealth &Envuotyrient
Dedicated to protecting and improving the health and environment of the people of Colorado
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Regulation Number 3, Part D, VI.B.4/V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
Facility
Equipment
ID
AIRS
Point
Equipment
Descri tion
p
Pollutant
Emissions - tons per year
Threshold
Current
Permit
Limit
GLENG01
002
SI RICE
VOC
NOx
50
50
18.0
8.5
PRD WTR
003
Produced
Water
Storage
Vessels
TANKS
004
Crude Oil
Storage
Vessels
LOAD
005
Hydrocarbon
Loadout
Separator
006
Separator
Venting
GEN01
007
SI RICE
GLENG02
008
SI RICE
VRU
009
SI RICE
___
Insignificant
Sources
tote: APEN and (permit exempt sources do not have permit limits. However. the PTE of
(excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR.
GENERAL TERMS AND CONDITIONS
22. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
23. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
Page 7 of 12
;COLORADO
Air Pollution Control Division
De linen a' Pubic Health & triyirc,oment
Dedicated to protecting and improving the health and environment of the people of Colorado
25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization section
of this permit.
24. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
25. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
26. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Harrison Slaughter, P.E.
Permit Engineer
Page 8 of 12
COLORADO
Air Pollution Control Division
"LTAlt-rie S 0' Pub1!_ ffei1Ui & Errercriroe
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit History
Issuance
Date
Description
Issuance 1
March 1, 2018
Issued to Enerplus Resources (USA) Corporation.
Issued directly to Final Approval.
Issuance 2
January 9, 2020
Permit modification Issued to Enerplus
Resources (USA) Corporation.
Issuance 3
This Issuance
Issued to Enerplus Resources (USA) Corporation
Decrease permitted throughput from 135,000
barrels/year to 90,000 barrels/year. Add VRU as
control device. Update to reflect current
regulatory requirements.
Page 9 of 12
I COLORADO
Air Pollution Control Division
Decafvne.ni ce Pubis_ Health t, apercrveneni
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the
Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
005
Benzene
71432
66
2
Toluene
108883
18
1
Ethylbenzene
100414
2
0.1
Xylenes
1330207
5
0.2
n -Hexane
110543
389
13
224 TMP
540841
14
0.5
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 10 of 12
COLORADO
Air Pollution Control Division
Decaarunent ey Putii_ nevi) 6 _nvvuarYIEn1
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Point 005:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/bbl)
Controlled
Emission Factors
When Emissions
are Routed to
the VRU
(lb/bbl)
Controlled
Emission
Factors
During VRU
Downtime
(lb/bbl)
Source
CO
5.69x10-4
---
5.69x10-4
AP -42
Chapter
13.5
VOC
1.01x10-1
0.00
5.04x1O3
AP -42
Chapter
5.2,
Equation 1
110543
n -Hexane
4.32x10-3
0.00
2.16x10-4
The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95)
using the following values:
L = 12.46*S*P*M/T
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 3.4 psia
M (vapor molecular weight) = 50 lb/lb-mol
T (temperature of liquid loaded) = 530 °R
The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by
multiplying the VOC emission factor by the ratio of the each NCRP mass fraction to the VOC mass fraction
in the vapors.
The controlled emissions factors for this point are based on a control efficiency of 100% when emission are
routed to the VRU and a control efficiency of 95% when emissions are routed to the enclosed combustor(s)
during VRU downtime. Uncontrolled actual VOC and HAP emissions are calculated by multiplying the
emission factors in the table above by the total hydrocarbon liquid loadout throughput. Controlled actual
VOC and HAP emissions are calculated by multiplying the uncontrolled emissions by a 100% control
efficiency when emissions are routed to the VRU and a 95% control efficiency when emissions are routed
to the enclosed combustor(s) during VRU downtime. The AP -42 Chapter 13.5 CO emission factor (0.31
lb/MMBtu) in the table above was converted to units of lb/bbl using a GOR of 0.76 scf/bbl and heat
content of 2,405.16 Btu/scf. Actual CO emissions are calculated by multiplying the emission factors in the
table above by the total hydrocarbon liquid loadout throughput during VRU downtime.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Page 11 of 12
'COLORADO
Air Pollution Control Division
Dereturient zit %U'lr_ Health & r iOfiyrle v
Dedicated to protecting and improving the health and environment of the people of Colorado
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, NOx, CO Et n -Hexane
PSD
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC Et NOx
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.60O-63.1199
Subpart AA -: Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 12 of 12
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer:
Package #:
Received Date:
Review Start Date:
Harrison Slaughter
423294
12/18/2019..
9/2/2020
Section 01- Facility Information
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility: Exploration & Production Well Pad
What industry segmentiOil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? Yes
If yes, for what pollutant? Ozone (NOx & VOC)
Enerplus Resources (USA) Corporation
123
9F50
Canadian Slang Well Pad.
Weld County
Section 02 - Emissions Units In Permit Application
Leave Blank - For Division Use Only
AIRs Point 4
(Leave blank unless
APCD has already
assigned)
Emissions Source Type
Equipment Name
Emissions
Control?
Permit 9
(Leave blank unless
APCD has already
assigned)
Issuance
#
Self Cert
Required?
Action
Engineering
Remarks
005
Liquid Loading
LOAD
Yes
17WE1205
3
No
Permit
Modification
Quadrant
Section
Township
Range
SESW
36.
8N
67
Section 03 - Description of Project
Enerplus submitted a permit application to modify sources at an existing major well production facility. With this application, the operator is requesting to
modify the crude oil storage vessels, hydrocarbon loadout and separator venting sources. This analysis only evaluates the hydrocarbon loadout.
With this application, the operator is requesting to decrease the permitted throughput from 135,000 barrels/year to 90,000 barrels/ year. In addition, the
operator is requesting the use of a vapor recovery unit (VRU) to control a portion of the emissions. This request correlates to emissions associated with 30,000
barrels of production being controlled by the VRU and the emissions associated with the remaining 60,000 barrels of production are routed to and controlled by
the enclosed combustors. The permit was also updated to include current regulatory requirements and citations.
Public comment will be required for this permit modification because new synthetic minor limits are being established. In other words, the facility emissions are
now below the serious non -attainment threshold of 50 tpy.
The first two issuances of this permit were issued as final approval. The modifications as a result of this project do not warrant sending the permit back through
the self -certification process. As a result, the permit will be issued as final approval.
Sections 04, 05 &
06 - For Division Use Only
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requiremer
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes, indicate programs and which pollutants: SO2 NOx CO
Prevention of Significant Deterioration (Pm)) ❑ ❑ ❑
Title V Operating Permits (OP) ❑ O O
Non -Attainment New Source Review (NANSR) O
Is this stationary source a major source? No
If yes, indicate programs and which pollutants: SO2 NOx CO
Prevention of Significant Deterioration (PSD) ❑ ❑ ❑
Title V Operating Permits (OP) ❑ ❑ ❑
Non -Attainment New Source Review (NANSR) O
VOC
O
O
O
VOC
❑
❑
O
PM2.5 PM10 TSP
❑ ❑
El ❑ ❑
PM2.5 PM10 TSP
❑ ❑
❑ ❑ ❑
HAPs
O
HAPs
❑
Hydrocarbon Lo4dcut Emissions Inventory
Sec0on 01- Administrative lnrormamn
Faclliry AIRS ID:
123
County
9(50 005
Plant - Paint
Section 02 -Equipment Description Details
Detailed Emissions Unit
Description:
Hydrocarbon ....from from storage vessels to tanktr cks rising submerged 00.
Emission Control Device Emissions remitting from the loadout operation are captured using vapor balance. A vapor recovery unit (2R11) routes these ern2sio
Description: t safesmined
pipeline. Emissions are med to enclosed combustors during VRU downtime:
Is this loadout controlled? yes
Requested VRU Control Efficiency 91: 100
Requested Enclosed Combustor Control Efficiency
VRU Downtime %: 66.6]
Requested Overall 500 & HAP Control Efficiency %:
Section 03 . Processing Rate Information for Emissions Estimates
Primary Emissions- Hydrocarbon Loadout
Actual Volume Loaded =
Actual Volume Loaded During VRU. Downtime =
(Requested Permit Umit Throughput=
Requested Permit Umit Throughput During VRU Downtime =
Potential to Emit (PTE) Volume loaded =
Potential to Emit (PIE) Volume Loaded During VRU
Downtime =
Secondary Emissions -Combustion Device(s)
Heat content of waste gas=
Actual Volume of waste gas emitted per year =
Requested Volume of waste gas emitted per Year=
Actual heat content of waste gas routed to combustion device =
Requested heat content of wane gas routed to combustion device=
wig 5000 Barrels (bbl) per year
Barrels )bbl) per year
.000 Barrels )hbl) per year Requested Monthly Throughput =
Barrels )bbl) per year
90,000 Barrels )bbl) per year
Barrels )bbl) per year
405.16 Btu/scf
scf/year
xcf/Year
Potential to Emit (PIE) heat content of waste gas routed to combustion device =
MMBTU per year
_:r MMBTU per year
-_v MMBTU per year
Control Device
Pilaf Fuel Use Rate:
Pilot Fuel Gas Heating Value:
sin
Btu/scf
MMscf/yr
i.- MMBTU/yr
Section 04-Emisslons Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions)
Are the emissions factors based on a stabilized hydrocarbon 03010 sample drawn at the fad
permitted?
Loading Lass Equation
L=12.46e5rP'M/T
sr.
0.)63415266
Barrels (Ishii per month
Factor
Meaning
Value
Units
Source
5
Saturation Factor
{�
APd2 Ctppters2 mote5.2-15ubmerged taadnsg:0e0io esd Normal 5enrce(1.1.0)I l=
P
True Vapor Pressure
3.4
.- 28-02 Chapter ) Table ].1-2(Midconlnent Crude 00)- See Note In Section 00
M
Molecular Weight of Vapors
50.
Ih/Ib.mol
AP -42 Chapter) Table 7.1-2 )Middontinem Crude Oil)
T
Liquid Temperature
530 :.
Rankine
Operator Specified Value
L
Loading Lasses
-:16/1000 gallons
I b/bb1
Component
Mass Fraction
Emission Factor
UnitsSource
Benzene
Ih/bbl
Total Waste Gas Composition IMP Tank)
_
Toluene
-
Ib/bbl
Ethylbenzene
'-1b/bbl
xylene
_
Ib/bbl
n xexane
lbrom
224TMP
,
'
Ib/bbl
Emission Factors
Hydrocrbon toadoM
Emission Factor Source
Pollutant
Uncontrolled Controlled
)lb/bbl)
lib/bbl)
(Volume Masker
(Volume Laded)
VOC
Site Sp cifi-AIX,
Site Spectre -ABA
Ste Specific -8842 1
Site Specific - APx42:-' `Y
Site 5pe2Oc-AP-42 Cho
Site Specific -AP -42 Chap4ws 1'"•' 1
SiieSpecific- ABC, Ctrs -
Benzene
Toluene
Ethylbenzene
Xylene
94lexane
-..
224TMP
-
_r-
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (lb/bbl)
(waste heat combusted)
(volume Loaded)
PM10
0.0075
AP-42Table 1.42(PM30/PM.2.9(
AP -42 Table 1.42 (PMSO/PM.d.S(
AP 42Table 1.4-2 (50x)
AP -02 Chapter 13.5 IndustrtalTtrees (NO,)
AP -42 Chapter 13.9 lndustmi Flares ([0)
PMLS
0.00)5
50x
0.0006
NOx
0.0680
CO
0.3100
Pollutant
Pilot Light Emissions
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (Ib/MMscf)
(Waste Heat Combusted)
(11101 as
Throughput)
PM10
PM2.5
SOx
NOst
VOC
CO
Molecular Weight:
mole%
MW
Ibx/Ibmol
mass fraction
Helium
0.00
4.0026
CO2
1.14
44.01
N2
: 0.12
28.013
methane
15.43
16.041
-.
ethane
Propane
40.90
44292
isobutane
2.]4
58.110
mbutane
12.35
58.118
1.)4
]2.15
nwentane
2.10
)2.15
psuedo 1
0.62
104.41
n -Hexane
1.71
86.18
_.
psuedo 2
0.00
186.60
Otherhexanes
2.70
84
pniedo 3
0.00
29).63
-.
methyleyeloh3xane
D.00
98.19
224-TMP
;' 0.05
114.23
..
Benzene
Toluene
:. 0.03
92.14
Fthylbenzene
0.01
106.1]
xylenes
0.02
106.1)
CBs Heertes
0.00
116
Total Mole %
VOC mole %
Controlled Emission Factors U ed In Permit
Controlled
Controlled
Emission
Emission
Factors used
during VRU
Factors Used
During VRU
Operation
Downtime
Pullmans
)lb/bbl(
ilb/bbl)
Source
VOC
_.
_B
SitespecificE.F.
Benzene
Toluene
-:.
Site specific E.F.
15910enzene
Site spe2fic E.F.
3ylene
Site specific E.F.
it -Hexane
-
Site specific E.F.
224TMP
-.
Ste specific E.F.
vac mass fraction.
0f4
C:\Users\hslaught\Desktop\ 1239F50\1)WE1205.CP3
Hydrocarbon 'Loado f Emissions Inventory
Section OS- Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
Imes/year)
Actual Emissions
Uncontrolled Controlled
(tens/year) (tons/year)
Requested Permit Umks
Uncontrolled Controlled I
Irons/year) an s/marl
Requested Monthly Umin
Controlled
(Ibis/month)
PM10
PM2.5
SChi
NOx
Vat
CO
-
-
0.00
0
Oa)
-
r
335,
.
1
3,2
Hazardous Air Pollute.
Potential to Emit
Uncontrolled
gbs/mar)
Actual Emissions
Uncontrolled Controlled
Obs/yeet) (Ito/marl
Requested Perna..
Uncontrolled Controlled
dbs/year) Ilbs/year)
Benzene
Toluene
Ethylbenzene
Xylened
n -Hex
224TMP
.7
A.
0,60
r.
O.
13.76
1.43
Section O6 - RegulatorySummary Analysis
Regulation 3, Parts A, 0
Regulation 7 Part D Section ILLS.
(See regulatory applicability worksheet for detained analysis)
Section 07 -.Hal and Periodic Sampling and Test. Requirements
Does the company request a control device efficiency greater than 95%fora flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing In accordance with P5 Memo 20-02
Sectron 08 -Technical Analysis Notes
Y Accordingto the APEN,two wellsproduce to this facility. The well names and API numbers are as follows: H) Name: Maplefr-6T-36-2X, API: 05-123-44539, and (R) Name: Beaufort 8-67-36.25C, API: 05.12349310. The Maple well was fractured and began production in
I August 2017. This well produeesfrom the Cane, Codell and Tort Hays formation. The Beaufort well was fractured in luly2019 and began production in September 2019. COGCC data does not provide information on the formation from which this well produces. COGCC data
indicates the API gravity for each wail isleeethan 40.. result, the classification as crude oil is appropriate.
; 2 N -Hexane Is the only HAP. which emissions are above APEN reportingthresholds (i.e. 2501b/year). Asa result, it is the only HAP for which an emission factor's included in the permit.
The crude oil storage vessel, produced water storage vessels and toadout operations are controlled by the same two enclosed combanprs As a resuk, engineering guidance Indicates thateombustion emissions 6.e. NOx and CO)from all the sources are summed together in
orderto determine APENappllrabifty. Inthis rase, CO emissions from all the sources -are above APEN reponingthresholdo. Asa result the permit for each source should contain emission limits and emissionfa).tors CO.Taal NC%emissions from thecrude oil storage vessels,
produced water storage vessels and loadaut operations are below APENreporringthresholds,
4. According to engineer guidance, plot light emissions are grouped with thehgiest emitting source that is controlled by a common control deuce In this case the crude oil storage vessels are the highest emen mingsourcecontrolled by the closed combustors butoat this facility..
Asa result, pilot light ernIssiOnsaree aCuaCedvfiththeanalyslc for the crude oil storage vessels only (1TNE121M.CP3) - -
. The heat input rate ofloadout waste gasrouted to the ECDs was calculated Using the following equation: MMmu/year [Uncontrolled VOC(ton/year)I'l2002 lb/ton)/(Molecular Weight)Ibfb-mol)rt379 sef/lb-mol)'Ness Content (Btu/scf)j\[fr ,000 Btu/MMBtu). The
heat contentused in this equation's based onaweighted average of the value fn the CRP Tank simulation forthe flash gas stream and the working and breathing stream. The value is listed above In Section 03 of this analysis The molecular weightused in this equation refims
the molecular weight for midoontinerd crudeoil listed In AP -42 Chapter ?Table 7.1-2 ISOIb/Ibmol). It should be noted Mat only a portion of the total emissions are routed to the combustion device. Emissions routed the VRU do not result in combustion emissions. Asa result
the combustion calculations only acrauntfor emissions escalated with the throughput ranted the control device (ie. 60,000 6arreh).
6... March 2020, AP -42 Chapter 7was updated. One of the updates pertsirrs to the calculation of true vapor pressure fat liquid specified as midcon0nent crude oil. Based on the updates, the true vapor pressure for midcontinent crude oil is calculated using Equation 1-25 (AF-
42Chapter7) and Figure 7.1-16. Using an average RVP of 5.626 (see noble oil samplm in application), maximum daily average ambient emperatureet523.176, minimum deity average ambianttemperetre of 49757R, ayerege solar ebsorptan eof 049 (tin ineversge
condition), and average total insulation factor of 14910os/R^2day in conjunction alb the equations listed above, the true vapor pressure was calculated et 3.113 psi. Using this value, a bulk liquid temperature of 55.67'P and molecular weight of SOlb/ibmel, the VOC
emission factor was calculated at 0:U95 Ib/bbl.The operator's calculations resulted roan VOC emission factor of 0.100716/Lbl. Sincethe operator's olculations are avnservative,they were accepted and used for permitting purposes,
7.The mole%values from the totatwadagess m In the E&PTank simulatiortwere converted to weight %. The ratio ofthecalculated HAP weight 96 th to e VOC weight %was multiplied by the VOCemisssource.om this sourcedetermine the HAP emissions. These
conversions and calculations an, available for reference ence n Section 04 above.
S. An updated APEN was submitted in March 2020 This APEN Indicates that portion of emissions arecaptured using a vapor recovery unit (VRU). According to Me operator, emissions from the hydrocarbon Ioadoutare vapor balanced to the storage vessels and then routed
to o sales pipeline through the use of avapor recovery unit (VRU) during normal operation. During VRU downtime, emissions from the hydrocarbon loadout are eapor balanced to the storage vessels and then routed to enclosed wmbusta(s). The operator has indicated the
vapor recovery units are down for 6796 of the time during the calendar year. DuringliRU operation, the operator has requested a control efficiency of 10%5 During VRU downtime, the operator has requested a 95%control efficiency for the enclosed combusta(s). Since the
control dedces have different control efficiencies the operator will be requtredtotmck VRU downtime in conjunction with hydrocarbon liquid 'admit throughput during VRU downtime in order to demonstrate ongoing compliance. The permit will contain VRU downtime
tracking condition in conjunction with a process limit an hydrocarbon liquid loadoutthroughput during VRU downtime.
9. The permitwill containtwo process ...lb regards to hydrocarbon liquid'aadout throughput One Ilmit will reference total requested hydrocarbon liquid leadoutthroughput(90,000 barrel/year) The second limitwill reference total hvdroarbon liquid loaduut
throughput during VRU downtime (60,000 laurel/year). The limit ontotal hydrocarbon liquid lariat throughput incorporates all thetleaghput that occurs while the VRU is operational. In the event the VRU has less then 67% downtime (i.e. the hydrocarbon liquid leadout
throughput during VRU downtime is lass Menthe requested limit), the operatorshould remain in compliance with the emission limits because the VRU is requestinga 107% control efficiency compared to the95%contra efficiency associated with the enclosed combustor(s).
Asa result, less VRU downtime Is beneficial both for the environment and the operator.
j 10. The controlled VOC and HAP emission factors in Section 04 above. bas. on the overall control efficiency assoeiatedvritte the VRU (100% control) and enclosed combustor(s) (95% control). However, these emission factors are not the values that will be in the Notesto
tPermit Holder section ofine permit The Notes to Permit Holder in the permitsets of controlled emission factors, Thefirscset represents controlled emission factors that must be used when emissions are routed to the CRASiH,, a 100% control efficiency is
applied when emissions are routed" toy the VRU, the emission factors for this Scenario are all represented as OLD lb/bbi The second set of emission factors represents controlled emission factors that must be used when missions are routed to the enclosed combustor(s) during
VRU downtime. These emission facion representthe uncontrolled emission factors mdtplied by a 95% control efficiency. The controlled emission factors represented in the perms are calculated In a table in Section 04 above labeled "Controlled Emission Factors Used In
Permit" ..
The operator was prodded with a draft permit and UPON redlineto review priorto public comment The operator reviewed bath documents and expressed they had no comments.
Section 09 -SCC Coding and Emissions Factors )Far Inventory Use Only(
AIRS Point g
COS
Process
SCC Code
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 = ib/1,000 gallons transferred
PM25 0 5/1,000 gallons transferred
500 ddEPS d 6/1,000 gallons transferred
Sea 6/1,000 gallons transferred
VOC 1.3. b/1,000 gallons transferred
CO b/1,000 gallons transferred
Benzene - b/1,I100 gallons transferred
Toluene .. b/1,000 gallons transferred
Ethytbemene b/1,000 gallons transferred
anleneI b/1,000 gallons transferred
n -Hexane L.0.01 b/1,000 gallons transferred
224 TMP ...,., .. b/1,000 gallons transferred
3 of C:\Users\hdaugtrt\oesktop\2239F50\17WE32o5.CP3
Hydrocarbon Loadout Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions and throughput.
Colorado Regulation 3 Parts A and B -APEN and Permit Requirements
ui1 the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)?
lYOcr have Indicated that source is in the Nmt-Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 Weis per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than SIPS or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
1
Yes
Yes
No
No
N
Yes.'`:
'Source requires a permit
Colorado Regulation 7 Part D Section II.C.S.
1. Is this condensate storage tank hydrocarbon liquids loadout located at a well production facility, natural gas compressor station or natural gas processing plant?
2. Does the facility have a throughput of hydrocarbon liquids loadout to transport vehicles greater than or equal to 5,000 barrels?
Yes
IT be hydrucarbon liquids 4aac c;,., ,,,;,rc r. n, subseet to Kmautanoo 7 Part 0 Srccmo
Section II.C.5.a.(i) - Compliance Schedule
Section II.C.5.a.(ii) - Operation without Venting
Section II.C.5.a.(iii) - Loadout Equipment Operation and Maintenance
Section II.C.5.a.(Iv) - Loadout observations and Operator Training
Section II.C.5.a.(v) - Records
Section II.C.5.a.(vi) - Requirements for Air Pollution Control Equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document
is not a rule or regulation, and the analysis it contains may not apply toe particular situation based upon the individual facts and circumstances. This document does not change or substitute for any
law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its
implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend,""may,"
"should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under
the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Go to next question.
Go to the next question
Ga to next question
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The loadout requires a permit
Go to next question.
Source is subject to Regulation 7 Part D Section II.C.5.
COLORADO
Air Pollution Control Division
Ltantne,tt Putter Health 6 _nvitavne,n
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 17WE 1206 Issuance: 5
Date issued:
Issued to: Enerplus Resources (USA) Corporation
Facility Name: Canadian Slang Well Pad
Plant AIRS ID: 123/9F50
Physical Location: SESW Section 36 T8N R67W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Separator
006
Flaring of natural gas vented from two (2)
two-phase separators and two (2) three -
phase separators during gas pipeline
downtime.
Open Flare(s)
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
this specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may
result in revocation of the permit. A self certification form and guidance on how to self -
certify compliance as required by this permit may be obtained online at
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
2. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
Page 1 of 11
'COLORADO
Air Pollution Control Division
carvnera t au[Ale_. Neagh 6 J vv:f;unee 1
Dedicated to protecting and improving the health and environment of the people of Colorado
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
3. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
4. The operator must retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
Separator
006
---
---
6.8
2.4
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons
per year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve
month total is calculated based on the previous twelve months' data. The permit holder must
calculate actual emissions each month and keep a compliance record on site or at a local
field office with site responsibility for Division review.
6. The owner or operator must use the emission calculation methods and emission factors found
in the Notes to Permit Holder to calculate emissions and show compliance with the limits
contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice
(APEN) and receive a modified permit prior to the use of any other method of calculating
emissions.
Page 2 of 11
!COLORADO
Air Pollution Control Division
f .anrnent of Pubir Heath & Jivvuune,i
Dedicated to protecting and improving the health and environment of the people of Colorado
7. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Separator
006
Emissions from the two-phase separators
and three-phase separators are routed to
an open flare during gas pipeline downtime.
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
Section II.A.4.)
.A.4 )
Process Limits
Equipment ID
AIRS Point
Process
Process Parameter
Annual Limit
Separator
006
01
Natural gas vented from
two (2) two-phase
separators and two (2)
three-phase separators
and routed to the open
flare.
10.9 MMSCF
02
Combustion of pilot light
gas
0.2 MMSCF
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
9. The owner or operator must continuously monitor and record the volumetric flow rate of
natural gas vented from the two-phase separators and three-phase separators and routed to
the open flare using an operational continuous flow meter. The flow meter must be calibrated
and maintained per the manufacturer's specifications and schedule. The owner or operator
must use monthly throughput records to demonstrate compliance with the process limits
contained in this permit and to calculate emissions as described in this permit.
Page 3 of 11
COLORADO
Aix Pollution Control Division
Deoarunem o4 Pour_ Nee1th & Envuernte
Dedicated to protecting and improving the health and environment of the people of Colorado
10. The owner or operator must monitor and record the time (hours) during which gas vented from
the two-phase separators and three-phase separators is routed to and controlled by the open
flare. The time during which two-phase separator and three-phase separator gas is routed to
the open flare shall not exceed 744 hours (1 month) in a calendar year. The owner or operator
will calculate the total hours during which two-phase separator and three-phase separator gas
is routed to the open flare per calendar year and keep a compliance record on site or at a local
field office with site responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
12. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
13. The open flare covered by this permit has been approved as an alternative emissions control
device under Regulation Number 7, Part D, Section II.B.2.e. The open flare must have no visible
emissions during normal operations, as defined under Regulation Number 7, Part D, Section
II.A.23, and be designed so that an observer can, by means of visual observation from the
outside of the open flare, or by other convenient means approved by the Division, determine
whether it is operating properly. This open flare must be equipped with an operational auto -
igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d.
14. The separators covered by this permit is subject to Regulation 7, Part D, Section II.F. On or
after August 1, 2014, gas coming off a separator, produced during normal operation from any
newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be
routed to a gas gathering line or controlled from the commencement of operation by air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.
If a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
15. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division -approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING 5t MAINTENANCE REQUIREMENTS
16. Upon startup of this point, the owner or operator must follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
Page 4 of 11
"COLORADO
Air Pollution Control Division
I Ck wrtne!zt o' Put!lK: Healsh t Gn4rrorl le!
Dedicated to protecting and improving the health and environment of the people of Colorado
to the OEtM plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
17. The owner/operator must complete an initial site specific extended gas analysis ("Analysis")
within one hundred and eighty days (180) after commencement of operation or issuance of
this permit, whichever comes later, of the commingled natural gas vented from the two-
phase separators and three-phase separators in order to verify the VOC, benzene, toluene,
ethylbenzene, xylenes, n -hexane, 2,2,4-trimethylpentane and hydrogen sulfide content
(weight fraction) of this emission stream. Results of the Analysis must be used to calculate
site -specific emission factors for the pollutants referenced in this permit (in units of
lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be
submitted to the Division as part of the self -certification and must demonstrate the emissions
factors established through the Analysis are less than or equal to, the emissions factors
submitted with the permit application and established herein in the "Notes to Permit Holder"
for this emissions point. If any site -specific emissions factor developed through this Analysis is
greater than the emissions factors submitted with the permit application and established in
the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a
timeframe as agreed to by the Division, a request for permit modification to address these
inaccuracies.
Periodic Testing Requirements
18. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
19. All previous versions of this permit are cancelled upon issuance of this permit.
20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section .I II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
Page 5 of 11
COLORADO
Mr Pollution Control Division
De anitient e+ Pubie H?a1t i 6 _nv rcrvnen1
Dedicated to protecting and improving the health and environment of the people of Colorado
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on
the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
Whenever a permit limitation must be modified; or
No later than 30 days before the existing APEN expires.
21. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Regulation Number 3, Part D, VI.B.4/V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
Facility
Equipment
ID
AIRS
Point
Equipment
Description
Pollutant
Emissions - tons per year
Threshold
Current
Permit
Limit
GLENG01
002
SI RICE
VOC
NOx
-
50
50
18.0
8.5
PRD WTR
—
003
Produced
Water
Storage
Vessels
TANKS
004
Crude Oil
Storage
Vessels
LOAD
005
Hydrocarbon
Loadout
Page 6 of 11
COLORADO
Air Pollution Control Division
Detaqment c Publ:c Health b Envvcrnrtie�°
Dedicated to protecting and improving the health and environment of the people of Colorado
Separator
006
Separator
Venting
GEN01
007
SI RICE
GLENG02
008
SI RICE
VRU
009
SI RICE
_
Insignificant
Sources
lote: APEN and permit exempt sources do not have permit limits. However. the PTE of
hese sources
(excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR.
GENERAL TERMS AND CONDITIONS
22. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
23. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization section
of this permit.
24. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
25. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
26. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
Page 7 of 11
!COLORADO
Mr Pollution Control Division
O€ rartrte!,t e! F jb] htealt!'i 6 Envi:c vee+x
Dedicated to protecting and improving the health and environment of the people of Colorado
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Harrison Slaughter, P.E.
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
March 1, 2018
Issued to Enerplus Resources (USA) Corporation.
Issuance 2
April 2, 2018
Issued to Enerplus Resources (USA) Corporation.
Modification to allow use of open flare during
well startup and during periods of noise and
vibration.
Issuance 3
July 2, 2018
Issued to Enerplus Resources (USA) Corporation.
Modification to increase gas throughput amount,
and to change control device equipment. Issued
as Initial Approval.
Issuance 4
January 9, 2020
Issued to Enerplus Resources (USA) Corporation.
Modification to increase process limit. Final
Approval Issuance.
Issuance 5
This Issuance
Issued to Enerplus Resources (USA) Corporation
Decrease permitted throughput from 127.9
MMscf/year to 10.9 MMscf/year. Update to
reflect current regulatory requirements.
Page 8 of 11
COLORADO
Air Pollution Control Division
Ck rir?veal cr! Path_ Heahh b Invirorment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the
Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the sources operates at the permitted
limitations.
Equipment
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
Separator
006
Benzene
71432
298
15
Toluene
108883
458
23
Ethylbenzene
100414
628
31
Xylenes
1330207
832
42
n -Hexane
110543
3,460
173
2,2,4-
Trimethylpentane
540841
89
4
Hydrogen Sulfide
7783064
4
0.2
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportab e and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 9 of 11
COLORADO
r Pollution Control Division
r1c e,� Pubic HealtIi 6 ::nwcnmc=rr.
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Point 006:
Process 01: Waste gas vented from the two-phase separators and three-phase separators and
routed to the open flare.
CAS #
Pollutant
Weight %
of waste
gas
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
CO
---
432.2
432.2
AP 42 Chapter
13.5
VOC
36.98
24,704.73
1,235.24
Gas Analysis
71432
Benzene
0.041
27.37
1.37
Gas Analysis
108883
Toluene
0.063
42.0
2.1
Gas Analysis
100414
Ethylbenzene
0.0864
57.62
2.88
Gas Analysis
1330207
Xylene
0.1145
76.37
3.82
Gas Analysis
110543
n -Hexane
0.4758
317.44
15.87
Gas Analysis
dote:
e controlled emissions factors for this point are basedon the open flare control efficiency of 95%. The VOC
and HAP emission factors isted above are based on a site specif c two-phase separator extended gas
analysis obtained from the Maple 8-67-36-25C well on 10/09/2017. The mole % values from the sample
were converted to weight %. The calculated weight % values and molecular weight along with the
displacement equation (EPA Emission Inventory Improvement Publication: Volume II, Chapter 10) were
used to determine the emission factors. The sample temperature and pressure are 57°F and 18 psig
respectively. The CO emission factor above was obtained by multiplying the AP -42 Chapter 13.5 CO
emission factor (0.31 lb/MMBtu) by a higher heating value of 1394.2Btu/scf. Actual emissions are
calculated by multiplying the emission factors in the table above by the total metered two-phase and
three-phase separator gas routed to the open flare.
Process 02: Combustion of pilot light gas
CAS #
Pollutant
Weight %
of waste
gas
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
CO
---
432.2
432.2
AP -42 Chapter
13.5
Note: The CO emission factor above was obtained by multiplying the AP -42 Chapter 13.5 CO emission factor (0.31
lb/MMBtu) by a higher heating value of 1394.2 Btu/scf. Actual emissions are calculated by multiplying the
emission factors in the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is
based on a constant rate of 20.8 scf/hr. There is one flare equipped with a single pilot light that controls
emissions from this source. The total volume of pilot gas flow is determined by monitoring the hours the
open flare operates with an operational pilot light.
Total actual emissions are obtained from the sum of emissions resulting from the waste gas
vented from the two-phase and three-phase separators (process 01) and the combustion of pilot
light gas (process 02).
Page 10 of 11
COLORADO
Air Pollution Control Division
ftrneni 6` PutIe: Health & Enviro mt 1
Dedicated to protecting and improving the health and environment of the people of Colorado
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, NOx, CO & n -Hexane
PSD
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC Et NOx
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the following website: http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 11 of 11
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package 8:
Received Date:
Review Start Date:
For Division Use Only
Harrison Slaughter
423294
12/18/2019
9/9/2020
Section 01- Facility Information
Company Name: Enerplus Resources (USA) Corporation
County AIRS ID: 123
Plant AIRS ID: 9F50
Facility Name: Canadian Slang Well Pad
Physical
Address/Location:
County:
Type of Facility: Exploration & Production Well Pad
What industry segmentiOll & Natural Gas Production& Processing
Is this facility located in a NAAQS non -attainment area? Yes
If yes, for what pollutant?
Weld County
Section 02 - Emissions Units In Permit Application
Leave Blank - For Division Use Only
AIRs Point #
(Leave blank unless
APCD has already
assigned)
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
(Leave blank unless
APCD has already
assigned)
Issuance
#
Self Cert
Required?
Action
Engineering
Remarks
006
Separator Venting
Separator
Yes '
17WE1206
5
Yes
Permit
Modification
Ozone (NOx & VOC)_.
Quadrant
Section
Township
Range
SESW
36
SN
67
Section 03 - Description of Project
Enerplus submitted a permit application to modify sources at an existing major well production facility. With this application, the operator is requesting to
modify the crude oil storage vessels, hydrocarbon loadout and separator venting sources. This analysis only evaluates the separator venting source.
With this application, the operator is requesting to decrease the permitted throughput of gas routed to and controlled by a flare from 127.9 MMscf/year to 10.9
MMscf/year. The permit has also been updated to reflect current regulatory requirements.
Public comment will be required for this permit modification because new synthetic minor limits are being established. In other words, the facility emissions are
now below the serious non -attainment threshold of 50 tpy.
Self -certification for the third issuance of this permit was submitted on 08/17/2018 and approved on 08/20/2018. The fourth issuance of this permit was issued
as final approval. As discussed in this analysis, initial testing is required with this modification,..therefore the permit will be issued as initial approval.
Sections 04, 05 &
06 - For Division Use Only
Section 04- Public Comment Requirements
Is Public Comment Required?
Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requiremer
Was a quantitative modeling analysis required?
No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
No
Is this stationary source a synthetic minor?
Yes
If yes, indicate programs and which pollutants: SO2
NOx CO
VOC
PM2.5 PM10 TSP
HAPs
Prevention of Significant Deterioration (PSD) 0000
❑
❑
Title V Operating Permits (OP) ❑
El 0
El
❑
❑ ❑
2
Non -Attainment New Source Review (NANSR)
❑'
❑'
Is this stationary source a major source?
No
•
If yes, indicate programs and which pollutants: 502
NOx CO
VOC
PM2.5 PM10 TSP
HAPs
Prevention of Significant Deterioration (POD) ❑
❑ ❑
❑
❑
❑
Title V Operating Permits (OP) , 0000
Non -Attainment New Source Review (NANSR)
0 O
❑
000
Separator Venting Emssions Invenntor/
Senn 01 -Administrative Information
104145 AIM lo:
123
County
9F50
)rant
Sectlan 02 -Equipment Description Details
Detailed Emissions Unit Description,
Emission Control Device Description: Emissions from the Iwo -p
Requested Overall VOC & HAP Control Efficiency %. 95
o (2)tw0-phase and two (2) three-phase eeparato
limited Process Parameter Natural Gxa Vent04r�:.
Gas meter
5eNon 03 -Processing Rate Information for Emissions Estln®tes
Primary Emissions -Separator
Actual Throughput
10.9 MMscf Per Year
rs and three-phase separators are routed Walloper, fare during pipe000 dow.frne
Requested Permit LimitThmugh 10.9 MMscf per year
Requested Monthly Throughput= MMscf per month
Potential to Emit (PTE)Throughput= ;.^ MMzcf per year
Secondary Emissions-Comhustion Devices) for ally Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Control Devitt
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
1304.2 Stu/scf
MMzcf/yr
..- DINIBt.yeor
Section 04 -Emissions Factors&Methodologies
Description
Thetwo (2)welsatthe bonadlan Slang Well Pad protlure a two (2) inlettwo-phase separators. Mixed liquid from the two-phase separator Is routed to two (2)threephase separators for further separation. The gas from the two-phase
separators and three-phase separators h commingled and rouasd to Me open flare. be controlled during gas pipeline downtime. A site-spedflc pressurized two-phattseparator ga sample was ohtained from the Maple 8.6796-25C well o0
10/00/2017.76etemperaiureand pressure ofthesample are 57trand 18 psis respectively, The operator reed the mole %values from the samples-MI.161a%,These wkula0ons are shown below- The weight and molecular weight
from We sample along,aW the dhplarement equation (shown b low)were used to estimate emissions from thbsal,,e.
' lib/Ib-m01 Displacement Equation
Ex=4• MW• Xx/C
Il/Ihmal
Mole
Hydrogen Sulfide
CO2
N2
methane
ethane
propane
isobutane
n -butane
MW
Weight%
2,1]58
2:5764
64.3109
13.1708
10,4646
12917
3.6342
0,]430
0.8171
0:0442
0.1398
0.0171
0,2161
03271
0,0241
0.0027
0.0133
0,0173
0.0206
0.0273
00676
44.01
28.02
16.04
30,07
44,09
58,12
58.12
72.15
72,15
70.13
06.18
84,16
85,00
10010
98,18
11422
]8,11
opentane
pentane
ryclopentane
milexane
cyclahexane
Other hexanes
heptanes
methrcynohexane
224-TMP
Benzene
Toluene
Ethylbenzene
Xylenes
C8+ Heavies
106,17
106,17
120.00
Total
VOC Mole %
Total
VOC Wt%
Emission Factors
Sepa ator Venting
Emission Factor Source
Pollutant
Uncontrolled Controlled
(ll/MMsctt osMMscf)
(Gas Throughput)
(GasThroughputI
VOC
ianalygiP
gas wlysrs
gas enelysb
#S 3Mgas analyss
`r 2ed gasarelysII
1 - =Extended gas analysis
,T Extrrr0,04 analysis
'-Stde"Q&as`analysls
Benzene-
Toluene
i Ethylhenzene
Xylene
n-liexane-.
224TMP
Hydrogen sulfide,
Pollutant
PfirearyContral Device
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MM6tu) Il/MMscf
(Was. Heat
Combustedl
(Gas Throughput)
PM10
0.0075-
AP -42101 44-2(PM30/PM.2.5)
9R42Toble: 1424PM10/PM.0.5)
20 a3Spbie go -2 500)
_ �4{yyMeWai;lures(60x)
, 7gpustr(al Flares (CO)
PM25
0.0075
SOx
0.0006
_NOx
68
0.00
-
Co
03300
Pollutant
Pilot star Emissions
Emission Factor Source
Uncontrolled Uncontrolled
(ILM /MBtu) Il/MMzcf
(Waste Heat
Combusted)
(Pilot Gas Th roughput)
PM10 •
00075 .
..
ty"
44 Flares(NCI.
.,.. t.6. 3ryoC)
yAP 'CJs:5s@r"j5Md.., Fier. (CO)
PM2.5
Sox
O.06
NOR
0.0680
-
VOC
0.0054
CO
03100-.
-4 _
Section OS- Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled -
(cons/year)
Actual Eml sions
Uncontrolled Controlled
ltons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
bens/year) Irons/year)
Requested Monthly Limits
Controlled
(fibs/month)
PM10
PM2,5
SOx
NO4
CO
0.Od
r.
- .0.00
.00
0.53
0..
0.53
0.53
7
Hazardous w, Paiwtants
Potential to Emit
Uncontrolled
llbs/year)
Actual Emi slam
Uncontrolled Controlled
Im:/year) Iles/year)
.quested Permit Limits
Uncontrolled Controlled
llbz/,earl pbs/year)
Benzene
Toluene
Ethylhenzene
X]lene
n -Hexane
224 TRAP
Hydrogen Sulfide
-.
T..':.
_
_40
...IC
NOSY
-
1.4/
_
0/1
1. 1
.lit
2 oft
D\Users\hslaught\Deskep\1239F50\17WE1206.CP5
section as-Regulatory Summary Anal,.
Regulation 3,,Parts A,B
Regulation 7,Part o,Section II.B,F
Regulation 7,Part D,Section Haze
(See regulatory applicability worksbeetfor detailed analysis)
Section 07-Initial and pedodicsampling and Testing Requirements
Using Throughput.Monitor compliance
Does Gas the company use site specific emission factors based on a gay sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRS I0,and should have been collected within one year of the application received date.However,if the hality has not
been modified(e.g.,m new wells brought online),then It maybe appropriate to use an older sit-specific sample.
If no,the permit will contain an"Witt Testing Requirement"to collect a sitespeuficmas sample from the equipment being permitted and conduct.emission toter analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application.
Are-facility-wide permitted emissions of VOC greater that or equal to 40 tans per year in Me ozone nanattalement area
OR are emissions greater than or equal to 90 tons per year In the ozone attainment area?
If yes,the permltwll l contain:
-An"In Mal Testing Requirement"to cellecta site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less
than or equal to the emissions factors established with thls application.
-A"Periodic Testing Requirement.'to colhecta site specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less
than or equal to the emissions factors established with this application on anaemia]basis.
Will the operator have a meter Installed and operational upon startup of this point, —
lino,the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational(not to exceed 180 days).This
condition will use the'Yohne ofwaste gas emitted per BBL of liquids throughput.iscf/bbil value in section 03.
•
Does the company request a control deuce efficiency greater than 95%for a flare or combustion device, y s n—,y "?,
If yes,the permit will contain initial and period!ccompliance testing in accordance with P5 memo
2.2.../rhillnil
liliqUVXPETIPMMPARRiMfgrthalegliftraflkgrifORONVIElleit4).W.GrUPUMAilliKeriMIMPERNflitli%
'POI,.d,10,'.91..ottliol'iritz4diathidl.himithil9w.v„),),,,,,,,,,,,,,,,cttirddittrithillithittuth i
us Analysis Notes section o -.-. .. --.. -.. -. ....
1.Acrnrding to the APED,rove welfsproduce to this facility.The well names and API numbers areas follows:(1)Name:Maple B-67-36-2SC,API:OS-123.44539,3nd till Name:Beaufort g67-35-25C,API:00-12349330.The Maple well was fractured and began.
production in August 2017.This well produces horn the Cattle,Codell and Fort Nays formation.The Beaufort wellwas fracturedinJuly 2019 and began production in September 2019.COGCC data des not provide information on the formation from which[.
well produces The existing.well s.have not been refractured or completed since they began production and no new wells have been added to the facility,Since the two(i)wells began production after August 1,2814,all the gas coming off the separators is
subject to CO AQCCRegulation?,Part D,.Secton MR.As such thcontrol devices are required to beenctosed or approved as analter emission control equipment.The Control deuce for the separators Is one Woe.flare.This control option was
originally approved with the application submitted on March 6,2018.The flare will continue to be approved as alternative emission control equipment In this issuance of the pemit for the following reasons:
jil The open flare is not Intended r0 be used as the primarycontrol device for the separators at tins facility.According to the application,the gas produced by the separators will primarily be routed to a gas pipeline.Oruywhen the gazpipell navailable will
the separator gas be routed to the open Rare
(litThe open flare has a minimum control efficiency of 9S%for hydrocarbon endssion and hos a menufernirer,s design gut amee 0898%destruction efficierey for hydrocarbons
pill The open flare will operate with no visible emissions,Is equipped with an auto Igniterend will be able to comply with the requirements of Regulation 7,Part D,Section II B.
(Iv)The open flare will not he used i0 control emissions from the crude oitor prod..water storage vessels at this facility.
Appropriate condition will be added to the permit in order to ensure these requirements are met on an ongoing basis.
2.PS Memo 15-03 was updated on January31,2019.With this update,alternative emission control equipment must be"usedas a backup emission control on a tempo2ry basis,not to exceed Smooth in calendar yeah.Asa result,the permit will coneina
condition that requires the operator mtrack the hours of operation of the open flare and demonstrate those haves do not exeed 744 hours(31 day month)in tied by
operator
a operator has indicated ed they are capable of complying with this new
requirement.It should be noted that the tst permit Issued limited the open flare 120 hours per year.This limit was based on projected usage information provided try the operator in dm alternative emisdon conrol equipment request form.This limit was not
taken to avoid major source requirements based.previous facility emissions information.Since the PS memo allows for flare usage up to 7.hours per year,the permYtwas updared according to the operator's request
3,According to the application,a single flow meter was Installed at the inletm the open Sara This meter measures total two-phase and three-phase separator gas that is routed to and controlled by the open fare during pipeline downtime,
4..According to Rio operator,the sample provided In the application and used to akulate emissions is only representative of twaphaseseparator gas routed to the flare This sample was obtained from the Maple 8-67-36-25C well at this facility on l0/00/2017
The operator indicated that the two-phase separator gas will be the majority of the gas routed to the flare However,this permit covers both...phase and three-phase mparator gas that Is routed to the flare Asa result,the operator will be required to obtain
an Initial sample that epresentetive of commingled two-phase and them-phaseseparator gas in order Po confirm the emission factors developed through th lysis eeither accurate or conservative.ttshwuldhefurther noted that the sample was
obreieed prior to the completion of the second well at this facillry.Due to the addition of the second we.the gas composition may have changed.This further supports the need far initial sampling to confirm the validiryof the emission factors.
S.There are no vapor recovery unit tVRLIM 0n location for separator gas Asa result,the operator has Indicated the produced gas from the all Me separators lseilM routed m a gas gathering pipeline of to the open flare during Mpeltre downtime.The gas.
aced to the pipeline isconidened t0 hive a 100%control efficiency and isnot required to be metered.As discussed above,a single flow meter h installed at this fantirye determine the volume of gas routed to the open flare.This flow meter only measures
the...silo-phase and three-phase separator gas that Is routed to ore open flare.Asa result tracking of pipeline downtime isnat required to determine the total volume of gas routed to and combusted by the open flare.
5.As indicated in Section 07 of this analysis,periodic sampling Is not required at this facility because permitted emission are fess than 40 thy.
1.CO emissions from this source are above APED reporting thresholds.As a result,the permit will contain a limit on this pollutant,This limit includes emission associated with plot light combustion.
g.A throughput limit is included in the permit for pilot light combustor Emission factorsarnd calculatlonmerhods for pilot lighrcombustlon emissions are ate included in the notes to permit holder.This information's included In the permit because pilot tight
emissions contribute to the overall emissions from this murce.Additionally it Is important to include this information because throughput tracking and emissions location methods are different than those used to estimate emissions based.the combustion
of separator waste gas.This clarity s important for accurately quantifying actuate..ozs at this facillty.lt should be notedthatehe VOC emission factor associated with pilot light combustion is not Included in the permit because the emissions are negligible
(0.0002 toy)and do not impactthe permitted limits. - -
9.Periodic opacity observation are addressed by the O&M plan.Asa result,the permit does not contain periodic opacitytesttng:It should be noted that the Initial opacity testing required in the flrstissuance of the permit was completed with the self-
certification thatwas submitted on08/17/2018and approved on OB/20/2016.As a result the initial opacity testing wasrcmwed in the previous issuance of the permit and des not need to be included in this issuances
30.The operator Indicated the open flare lead m control emission from this source does not[Ake any assistgas or supplemental fuel.
SL Traditfonally,emission faders.d emissions far separation equipment are determined using the weight%values and molecular weightinformation directly..the gas samples provided in the application.In thiscase,the operator chose to convert the
mole%values from the samples in the app5ation to weight%and use the atmiatdweight%and molecularweightvaloes to calculate emission.Using the weight%values directly from the samples provided,the trathtiorel method of calculation resuhed in
thetollowing emission factors:(i)V0C:24,725.6tb/MMscf,(II)Benzene:27.3416/MMecf,pil(roluene:42.11lb/MMscf,(iv)Ethnihereene:57.03 Ib/MMscf,(v)%ylene:76Abib/MN i,(vl)n-Hexane:318th/MMmf,(W1224TMP,B.021b/MMscf and(viii)
Hydrogen sulfide:0.3.lb/MMscf.The operator's calculations resulted lnemissionfactors that are either conservative or riegligibiy different than the values calculated using standard methods.As a result,the operator'seshmation were accepted and used for
Permitting purposes.
12.2,2,4TMP and hydrogen sulfide emissions are below APEN reporting thresholds lie,0054 lb/year).As a result emission factors for these pollutant will not be included in thepetint. 'a,**"
13.Traditionally,the deal gross heating value listed an the g pl(14.38 Btu/f)wouldbe usedf alooIetons.In this case,the operator chose m use the grass real(wet basis)heat content(3 /scf)to calculate emissions The opeate"0
provided the following reasoning,n a simlarapplicaton for using the chosen hoatvalue.I respectfully request we us the heating value we have demonstrated In the application,approved by previous permits amities b used for the path years for
feotlry.The value is based..aagpap GP hod and lze valid alculahonfor heat content The"ideal"Mattatheoretical for ideal gee and not"real•,merefinethe Neal.wet bessalculatetl heat moron has been d This hhow all of
vRi
Enerplus sites have been at up and for the k f onsistenncy,we do not want m have Goeste that has a different compliaice harking item than the rmL The other equipm.t at the site that's,.being modified...If Nvs.).as well The'rifle V gro up
used the term"lowest gross'for as long as I mn remember,they new use the term lower heating mi.,see excerpt template language.The Mat content of Me ai-oral gas used m fuel these.gines shall beverifiedennuaIN using the appropriate ASTM
Methods or equivalent,If approved in advance by the Division.The heat content of the natural gas shall be based.the lower tvtingvalue()Hirai the fuel.Results of the hat content veriflationshall be remin,tldmed aetdmade a+ailabie te the oivsien upon: ..
request Regardless,It 1st.same value.The'wetbasiz•means you don't Include the latent heat...at.of water in the combustion product,which tome seems like...approach.The vaporization of cater is not going to contribute to the
production of NOR 5r CO and therefore should not be Included In those calculations'Based a de operator's reasoning and the indistinguishable difference in total emission when using either value,the akulation provided by the operator were accepted for
permitting purposes.
10.The of p f this submitted As 03/07/2 updated N051 required asp oft.self-certification requirements In then it '..The operathrprovided with a draft permit and APENrdln o review lair to permit Issuance.the operator reviewed both document and provided comments.The operators comments and Division responses are available nthe emailecord i,
uploaded to Records Manager
/
•
seton o9-5CC Coding and Emissions Factors(For invert.,Use Onlyl -
AIRS Pohl. Proves. SCE Code Pollutant Uncontrolled Emissions Factor Control% Units
nos 01 4,0Oil 50 ottras PM10
SOx u RN..
NOx •— --
CO +'tt .,Mil's
Benzene
Toluene 42., YS PaiW:sr✓_
Ethyibenzene 57.5 )S I'5;'f"il-:_.F
Xylem T5.4 .
n-Heeane Ply 4 98 ti0ttos0
224 IMP 5 2 31 Ih/=a.ta"s;r
Hydrogen sulfide Z, 35 Ib/tt.?r'L-
3 of C\Veers\hshaught\Oesktep\123ae50\17WE3205.CP5
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below ore determined based on requested emissions.
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2TPY (Regulation 3, Part A, Suction II.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation3, Part B, Section 11.D.3)?
�yosi YUBwy. indicated that source is le the NGmiAt^tainment Areo
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
(Source requires a permit
Colorado Regulation 7, Part D, Section II
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
'Source is subject to Regulation 7, Part D, Sectiion 11,0.2, T'
Section 11.B.2 — General .Provisions for Air Pollution Control Equipment Used to Comply with Section II
Section II.F -Control of emissions from well production facilities
Alternative Emissions Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed?
The control device for ties separator is subject to Regulation 7, Part C;, Section u.B:Le
Section 11.B.2.e—Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document
is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any
law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its
implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend," "may,"
"should," and 'can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must' and "required"are intended to describe controlling requirements under
the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Yes
Source Requires an APEN. Go to the next question
Source Requires a permit
Yes -',Source is subject, go to next question
Yes":. f.I
Oee
Crude Oil Storage Tank(s) APEN
Form APCD-210
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the
General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A
list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division
(APCD) website at: www.colorado.gov/pacific/cdphe/air-permits.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
17WE1204
AIRS ID 123 / 9F50 / 004
Number:
[Leave blank unless APCD has already assigned a permit # and AIRS IDJ
Section 1 - Administrative Information
Company Name': Enerplus Resources (USA) Corporation
Site Name: Canadian Slang Well Pad
Site Location: SESW Sec 36, T8N, R67W
Mailing lu Address:
Code950 17th Street, Suite 2200
(Include Zip Code)
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Kristin Van Nees
Phone Number: 720-279-5515
E -Mail Address2: KVanHees@enerplus.com
' Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices wilt be issued by the APCD via e-mail to the address provided.
423291
Form APCD-21O Crude Oil Storage Tank(s) APEN Revision 7/2018 1
A®
COLORADO
o.,.,.Kavare w
Kt,* h ERY:Mfunt,I
Permit Number: 17WE 1204
AIRS ID Number: 123 /9F50/004
[Leave blank unless APCD has already assigned a permit # and AIRS IDI
Section 2 - Requested Action
❑ NEW permit OR newly -reported emission source
❑ Request coverage under traditional construction permit
❑ Request coverage under General Permit GP08
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
-OR-
❑✓ MODIFICATION to existing permit (check each box below that applies)
O Change in equipment O Change company name3
❑✓ Change permit limit O Transfer of ownership' O Other (describe below)
-OR -
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
▪ APEN submittal for permit exempt/grandfathered source
O Umit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info & Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Company equipment Identification No. (optional):
Six, 400 bbl Crude Oil Tanks
TANKS
For existing sources, operation began on: 8/18/2018
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24
Storage tank(s) located at:
hours/day 7 days/week 52
0 Exploration & Production (E&P) site
weeks/year
O Midstream or Downstream (non E&P) site
Will this equipment be operated in any NAAQS nonattainment area?
GI
Yes
O
No
Are Flash Emissions anticipated from these storage tanks?
12
Yes
■
No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)•
805 series rules? If so, submit Form APCD-105.
Yes
❑Q
No
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
GI
■
Form APCD-21O Crude Oil Storage Tank(s) APEN - Revision 7/2018
21
AV COLORADO
Permit Number: 17WE 1204
AIRS ID Number: 123 I 9F50/ 004
[Leave blank unless APCD has already assigned a permit r and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbl /year)
Requested Annual Permit Limits
(bbl/year)
Crude Oil Throughput:
60000 90,000
6000O 90,000
From what year is the actual annual amount?
2020
Average API gravity of sales oil: "-37 degrees
❑ Internal floating roof
Tank design: Ej Fixed roof
RVP of sales oil: --5.6
❑ External floating roof .
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production
(month/year)
Maple
3
1200
8/2017
8/2017
Beaufort
3
1200
7/2019
7/2019
Wells Serviced by this Storage Tank or Tank Battery6 (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 - 123 - 44539
Maple 8-67-36-25C
■
05 - 123 - 49310
Beaufort 8-67-36-25C
■
■
■
.
■
s Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 The EftP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.611048/-104.843942
Operator Stack
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
ECD1/ECD2
12
1000
Variable
Variable
Indicate the direction of the stack outlet: (check one)
0 Upward O Downward
O Horizontal
0 Other (describe):
Indicate the stack opening and size: (check one)
✓0 Circular Interior stack diameter (inches):
Square/rectangle Interior stack width (inches):
Other (describe):
❑ Upward with obstructing raincap
48
Interior stack depth
(inches):
Form APCD-210 - Crude Oil Storage Tankts) APEN - Revision 7/2018 3 1
AV
COLORADO
N.a��h tr E .vv�wwrwi
Redlines per updated application. (HDS 09/22/2020)
Permit Number: 17WE 1204
AIRS ID Number: 123 I 9F50/ 004
[Leave blan'r. unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Vapor
® Recovery
Unit (VRU):
Pollutants Controlled: VOC and HAPs
Size: NA Make/Model: EcoVapor G5CC
Requested Control Efficiency: 100
VRU Downtime or Bypassed (emissions vented): 67
❑ Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating:
Type: Enclosed combustors
MMBtu/hr
Make/Model: Cimarron ECD 48 SNs: 1356801, 1350071
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98+ %
Minimum Temperature: NA Waste Gas Heat Content:
Constant Pilot Light: J Yes O No Pilot Burner Rating:
2405
0.015
Btu/scf
MMBtu/hr
O Closed Loop System
Description of the closed loop system:
O Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -20
psig
Describe the separation process between the well and the storage tanks: Gas and liquids from each
well enter a heater treater. Gas, that isn't used for gas lift or fuel, is sent to sales. Oil is sent to
crude oil tanks and water is sent to produced water tanks. Separate battery for each well.
Redlines per updated application. (HDS 09/22/2020)
Form APCD-210 Crude Oil Storage Tank(s) APEN - Revision 7/2018
fl.partoetn, 1,410,
COLORADO
Permit Number: 17WE 1204 AIRS ID Number: 123 /9F50/004
[Leave blank unless APCD has already assigned a permit # and AIRS !Di
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form7.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (% reduction):
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
VRU and 2 ECDs
100% and 95%
NOx
CO
HAPs
VRU and 2•ECDs
100% and 95%
Other:
From what year is the following reported actual annual emissions data? 2020
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions8
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
VOC
3.59
lb/bbl
E&P Tanks
161.45
5.38
161.45
5.38
NOx
0.068
Ib/MMBtu
AP -42
0.2
0.2
0.2
0.2
CO
0.31
Ib/MMBtu
AP -42
0.93
0.93
0.93
0.93
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
g
Uncontrolled
Emissions
(pounds/year)
ye )
Controlled
Emissions8
(pounds/year)
Benzene
71432
2.60E-2
lb/bbl
E&P Tanks
2344
78
Toluene
108883
7.32E-3
lb/bbl
E&P Tanks
658.7
22
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
1.54E-1
lb/bbl
E&P Tanks
13,848
462
2,2,4-
Trimethylpentane
540841
5.45E-3
lb/bbl
E&P Tanks
490.7
16
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
7 Attach crude oil laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific
emissions factors according to the guidance in PS Memo 14-03.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Redlines per updated application. (HDS 09/24/2020)
Form APCD-21O Crude Oil Storage Tank(s) APEN - Revision 7/2018
COLORADO
lay
Permit Number: 17WE 1204
AIRS ID Number: 123 /9F50/004
[Leave blank unless APCD has already assigned a permit and AIRS ID1
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP08, I further certify that this source
is and will be operated in full compliance with each condition of the applicable General Permit.
12
Signature of Legally Authorized Person (not a vendor or consultant)
Kristin Van Hees
Date
Sr. Environmental Specialist
Name (print) Title
Check the appropriate box to request a copy of the:
El Draft permit prior to issuance
0 Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https://voNw.colorado.gov/cdphe/apcd
Form APCD-21O Crude Oil Storage Tank(s) APEN - Revision 7/2018
COLORADO
6 ,, ,
0EE
Hydrocarbon Liquid Loading APEN r
Form APCD-208
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require
payment for a new filing fee.
This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit,
condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN
options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution
Control Division (APCD) website at: www.colorada.govtcdphetapcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 17WE1205
AIRS ID Number: 123 / 9F50 / 005
019
[Leave bLank unless APCD has already assigned a permit # and AIRS ID)
Section 1 - Administrative Information
Company Name': Enerplus Resources (USA) Corporation
Site Name: Canadian Slang Well Pad
Site Location: SESW Sec 36, T8N, R67W
Mailing Address:
(Include Zip Code) 950 17th Street, Suite 2200
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Kristin Van Flees
Phone Number: 720-279-5515
E Mail Address2: KVanHees@enerplus.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that wilt appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
423290
COLORADO
Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 3/2019 1
Permit Number: 17WE1205 AIRS ID Number: 123 / 9F50'005
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑ NEW permit OR newly -reported emission source
O Request coverage under construction permit
O Request coverage under General Permit GP07
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
- OR -
O MODIFICATION to existing permit (check each box below that applies)
O Change fuel or equipment O Change company name3
Change permit limit ❑ Transfer of ownership' O Other (describe below)
- OR
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Truck Loadout of Crude Oil
Company equipment Identification No. (optional): LOAD
For existing sources, operation began on:
8/18/2017
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area?
Yes
No
p
■
Is this equipment located at a stationary source that is considered a Major Source of (HAP)
emissions?
Yes
No
•
O
Does this source load gasoline into transport vehicles?
Yes
No
■
1A
Is this source located at an oil and gas exploration and production site?
Yes
O
No
4
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual
average?
Yes
No
S
NI
Does this source splash fill less than 6750 bbl of condensate per year?
Yes
No
■
■
Does this source submerge fill less than 16308 bbl of condensate per year?
Yes
O
No
■
A COLOR ADO
Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 3/2019
Permit Number: 17VVE1205
AIRS ID Number: 123 I 9F501005
[Leave blank unless APCD has already assigned a permit a and AIRS !DI
Section 4 - Process Equipment Information
Product Loaded: ❑ Condensate El Crude Oil ❑ Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5:
90,000
bbl/year
This product is loaded from tanks at this facility into:
(e.g. "rail tank cars" or "tank trucks")
Actual Volume Loaded: [90,000 I bbl/year
Tank trucks
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:
0.6
Average temperature of
bulk liquid loading:
70
°F
True Vapor Pressure:
3.4 @70F
Psia ® 60 °F
Molecular weight of
displaced vapors:
50
lb/lb-mol
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loaded5:
bbl/year
Actual Volume Loaded:
bbl/year
Product Density:
lb/ft3
Load Line Volume:
ft3/truckload
Vapor Recovery Line Volume:
ft3/truckload
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Redlines per updated calculations. (HDS 09/23/2020)
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 3 I
AV
Deputraant
Permit Number: 17WE1205
AIRS ID Number: 123 / 9F50 1 005
[Leave blank unless APCD has already assigned a permit N and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
46.611048/-104.843942
Operates
Stack10 lio.
Discharge Height Above
l
Ground Level
(feet)
Temp,
f'f)
Flow Rate
(ACFM)
Velocity
(1t/sec)
ECD1/ECD2
32.8
1000
Variable
Variable
Indicate the direction of the stack outlet: (check one)
Q Upward
O Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
0 Circular
O Other (describe):
Interior stack diameter (inches):
❑ Upward with obstructing raincap
48
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
® Loading occurs using a vapor balance system:
Requested Control Efficiency: 100
❑ Combustion
Device:
Used for control of: VOC and HAPs (hack up to VRU)
Rating:
Type: 2-ECDs
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature: NA
MMBtu/hr
Make/Model: Cimarron ECD 48 SNs: 1356801, 1350071
95
98+ %
2405.12
'F Waste Gas Heat Content: 2623 Btu/scf
Constant Pilot Light: 0 Yes O No Pilot Burner Rating: 0.015 MMBtu/hr
® Other:
Pollutants Controlled: voc and HAPs
Description: VRU
Requested Control Efficiency: 100
Redlines per updated calculations. (HDS 09/23/2020)
Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 3/2019
Avc o l o R a D o
Permit Number: 17WE1205 AIRS ID Number: 123 / 9F50 / 005
[Leave blank unless APCD has already assigned a permit # and AIRS D]
Section 7 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (% reduction):
Pollutant
Description of Control Method(s)
Overall Requested
Control Efficiency
(% reduction in emissions)
PM
SOx
NO.
CO
VOC
Vapor Balance, VRU, and Combustors
100% / 100% I 95%
HAPs
Vapor Balance, VRU and Combustors
100%/ 100% / 95%
Other:
❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane
0 Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data?
2020
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
SOx
NO.
0.068
lb/MMBtu
AP -42
0.004
0.004
0.004
0.004
CO
0.31
lb/MMBtu
AP -42
0.02
0.02
0.02
0.02
VOC
2.4
lb/1000 gal
AP -42
4.53
0.15
4.53
0.15
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(pounds/year)
Controlled
Emissions 6
(pounds/year)
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.10
Ib/1000 gal
AP -42
388.8
13
2,2,4-
Trimethylpentane
540841
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 5 I
Redlines per updated calculations (HDS 09/24/2020)
tiZ�J
COLORADO
Ilep..Irtacrm tutu'°.,
Permit Number: 17WE 1205
AIRS ID Number: 123 / 9F50 /005
[Leave blank unless APCD has already assigned a permit land AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP07.
ti/\ j`) ►2 ik
3
Signature of Legally Authorized Person (not a vendor or consultant) Date
Kristin Van Hees
Sr. Environmental Specialist
Name (print) Title
Check the appropriate box to request a copy of the:
Q Draft permit prior to issuance
0 Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcci
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019
61
AV
COLORADO
u
114-1. 1 8 1019
Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require
payment for a new filing fee.
This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website at: www.cotorado.gov/cdphelapcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
17WE1206
123
AIRS ID Number: 1213/9F50 /006
[Leave blank unless APCD has already assigned a permit C and AIRS ID]
Section 1 - Administrative Information
Company Name': Enerplus Resources (USA) Corporation
Site Name: Canadian Slang Well Pad
Site Location: SESW Sec 36, TON, R67W
Mailing Address: 950 17th Street, Suite 2200
(include Zip Code)
Site Location
County: Weld
NAICS or SIC Code: 1311
Denver, CO 80202 Contact Person: Kristin Van Hees
Phone Number: 720-279-5515
E -Mail Address2: KVanHees@enerplus.com
I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. My changes wilt require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-211 - Gas Venting APEN - Revision 3/2019
423292
AVCOLORADO
Permit Number: 17WE 1206
123
AIRS ID Number: 1213 / 9F50 / 006
[Leave blank unless APCD has already assigned a permit and AIDS !D[
Section 2 - Requested Action
O NEW permit OR newly -reported emission source
-OR-
Q MODIFICATION to existing permit (check each box below that applies)
iI Change fuel or equipment 0 Change company name3 ❑ Add point to existing permit
0 Change permit limit 0 Transfer of ownership4 ❑ Other (describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Flaring of Separator Gas when pipeline
is unavailable
Company equipment Identification No. (optional):
For existing sources, operation began on:
Separator
9/12/2017
For new, modified, or reconstructed sources, the projected start-up date is:
0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
Operation:
Will this equipment be operated in any NAAQS
nonattainment area?
hours/day
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
days/week weeks/year
0 Yes ❑ No
0 Yes 0 No
0 Yes ❑ No
Form APCD-211 - Gas Venting APEN - Revision 3/2019 2
AV
Nya. Fe Env ovan•ro,
COLORADO
Permit Number: 17 WE 1206
AIRS ID Number:
123
1213 / 9F50 / 006
[Leave blank unless APCD has already assigned a permit .# and AIRS ID]
Section 4 - Process Equipment Information
O Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
Compressor Rod Packing
Make: Model:
❑ Slowdown Events
# of Events/year:
O Other
Description:
Serial #:
# of Pistons:
Volume per event:
Capacity: gal/min
Leak Rate: Scf/hr/pist
MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? Q Yes
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑ No
Vent Gas
Heating Value:
1394.2
BTU/SCF
Requested:
10.9
MMSCF/year
Actual:
10.9
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
25.32
VOC (Weight %)
36.98
Benzene (Weight %)
0.0410
Toluene (Weight %)
0.0630
Ethylbenzene (Weight %)
0.0864
Xylene (Weight %)
0.1145
n -Hexane (Weight %)
0.4758
2,2,4-Trimethylpentane (Weight %)
0.0122
Additional Required Information:
❑ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX 8 n -Hexane, temperature, and
pressure)
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
ANT CO & LORDO
Form APCD-211 Gas Venting APEN • Revision 3/2019 3 1 M
Redlines per updated calculations. (HDS 09/23/2020)
Permit Number: 17 WE 1206
AIRS ID Number:
123
1213/9F50/006
[Leave blank unless APCD has already assigned a permit 7 and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.611048/-104.843942
Operator
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
; Temp.
(•F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Flare
-15
1000
Variable
Variable
Indicate the direction of the stack outlet: (check one)
❑ Upward
O Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular
O Other (describe):
Interior stack diameter (inches):
O Upward with obstructing raincap
6
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency:
VRU Downtime or Bypassed:
❑ Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating:
Type: Open Flare Make/Model: Steffes
Requested Control Efficiency: 95
MMBtu/hr
hr
Manufacturer Guaranteed Control Efficiency: 98+
Minimum Temperature: NA Waste Gas Heat Content: 1394.2 Btu/scf
Constant Pilot Light: ❑ Yes O No Pilot burner Rating: 0.03 MMBtu/hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-211 Gas Venting APEN - Revision 3/2019
4
OLORADO
Redline per application. (HDS 09/23/2020)
Permit Number: 17WE1206
AIRS ID Number:
123
1213/9F50/006
[Leave blank unless APCD has already assigned a permit .; and AIRS ID[
Section 7 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (% reduction):
Pollutant
Description of Control Method(s)
Overall Requested
Control Efficiency
(% reduction in emissions)
PM
SO,
NO
CO
VOC
Open Flare
95%
HAPs
Open Flare
95%
Other:
From what year is the following reported actual annual emissions data?
2020
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual
Emission
Permit
Limit(s)5
Controlled
Emissions
(tons/year)
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tons/year)
PM
SOx
NO.
0.068
Ib/MMBtu
AP -42
0.53
0.53
0,53
0.53
CO
0.31
lb/MMBtu
AP -42
2.39
2.39
2.39
2.39
VOC
24.704.73
lb/MMscf
Mass Balance
134.64
6.73
134.64
6.73
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Emission Factor
Actual Annual Emissions
Uncontrolled
asis
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(pounds/year)
Controlled
Emissions6
(pounds/year)
Benzene
71432
27.37
Ib/MMscf
Mass Balance
298.4
14.9
Toluene
108883
42.00
lb/MMscf
Mass Balance
457.8
22.9
Ethylbenzene
100414
57.62
Ib/MMscf
Mass Balance
628.1
31.4
Xylene
1330207
76.37
lb/MMscf
Mass Balance
832.4
41.6
n -Hexane
110543
317.44
lb/MMscf
Mass Balance
3,460.1
173
2,2,4-
Trimethylpentane
540841
8.13
lb/MMscf
Mass Balance
88.6
4.4
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Redlines per updated calculations. (HDS 09/23/2020)
Form APCD-211 Gas Venting APEN - Revision 3/2019
51
mY
COLORADO
Permit Number: 17WE1206
123
AIRS ID Number: 1213 / 9F50 / 006
[Leave Prank unless APCD 'n as atready assigned a permit land AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
Signature of Legally Authorized Person (not a vendor or consultant)
Kristin Van Flees
Date
Sr. Environmental Specialist
Name (please print) Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
El Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692.3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https://www.coiorado.gavlcdphe/apcd
Form APCD-211 Gas Venting APEN - Revision 3/2019
61
COLORADO
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